Historic Properties Visual Impact Assessment: Addendum to Cultural Resources Evaulation

Rail Tie Wind Project Albany County,

Prepared for:

ConnectGen Albany County LLC

August 2020

Confidential Business Information. Do Not Distribute. Business Confidential ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project

TABLE OF CONTENTS

1 INTRODUCTION ...... 1 1.1 Project Background ...... 1 1.1.1 Wind Turbine Generators ...... 2

2 METHODOLOGY ...... 2 2.1 Initial Desktop Assessment of Cultural Resources ...... 2 2.2 Field Photography ...... 4 2.3 KOP Assessment ...... 5

3 RESULTS ...... 6 3.1 Determination of Effects Summary at Key Observations Points ...... 9 3.1.1 KOP 1: Tree Rock, ...... 9 3.1.2 KOP 2: Cherokee Trail Segment A ...... 9 3.1.3 KOP 3: Cherokee Trail Segment B ...... 10 3.1.4 KOP 4: Dale Creek Bridge ...... 11 3.1.5 KOP 5: Lincoln Monument ...... 12 3.1.6 KOP 6: , Segment 1; Willow Spring Station ...... 13 3.1.7 KOP 7: Overland Trail, Segment 14; CMM-JF-08 Extension (Union Pacific Railroad) ...... 14 3.1.8 KOP 8: VZW-A/B Overland Trail Segments ...... 15 3.1.9 KOP 9: Tie Siding Cemetery...... 15 3.1.10 KOP 10/11: Lodgepole Creek Trail A/B ...... 16 3.1.11 KOP 12: Hermosa (Sherman) Tunnel ...... 17 3.1.12 KOP 13: Barn at Oxford Horse Ranch ...... 18 3.1.13 KOP 14: Cheyenne Pass Road ...... 19 3.1.14 KOP 15: 1920 ...... 19 3.1.15 KOP 16: Granite 2 (Prehistoric Hunting Blinds) ...... 20 3.1.16 KOP 17: Cheyenne-Twin Mountains Wagon Road ...... 20 3.1.17 KOP 18: Ames Monument ...... 21 3.1.18 KOP 19: Willow Springs Bison Pound ...... 22

4 SUMMARY AND RECOMMENDATIONS ...... 22

5 LITERATURE CITED ...... 24

LIST OF TABLES

Table 1: Visual Impact Assessment Results and Determination of Effect for Historic Property Key Observation Points ...... 7

LIST OF FIGURES

Figure 1: Representative Project Layout (3MW) Figure 2: Representative Project Layout (6MW)

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Figure 3: Historic Property KOP Locations within the Area of Potential Effect Figure 4: Scenic Quality

APPENDICES

APPENDIX A: SWCA Cultural Resource Identification and Key Observation Point Selection Methodology (May 2020) APPENDIX B: Visual Contrast Rating Forms

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1 INTRODUCTION At the request of ConnectGen Albany County LLC (ConnectGen), Tetra Tech, Inc. (Tetra Tech) has prepared this Historic Properties Visual Impact Assessment Addendum (Addendum) to the April 2020 Cultural Resources Evaluation Technical Report (Tetra Tech 2020a) developed for the Project. This Addendum was also developed to complement the May 2020 Visual Impact Assessment (VIA) completed for the Project (Tetra Tech 2020b). This Addendum is intended to provide reviewing regulatory agencies with information on potential visual impacts of the Project upon historic properties within the 10-mile Project Area of Potential Effect (APE). The Western Area Power Administration (WAPA), in consultation with the Wyoming State Historic Preservation Office (SHPO) and Advisory Council on Historic Preservation as part of compliance with Section 106 of the National Historic Preservation Act (NHPA; 16 United States Code [USC] § 40 et seq.), has defined APE as:

the area within which historic properties [as defined at 36 CFR 800.16(l)(1)] may sustain loss of integrity (as defined in 36 CFR 60.4) by alteration or destruction caused by the proposed Project, and it includes 1) horizontally, the proposed Project footprint, which entails the physical footprint of all Project facilities within an approximately 26,000-acre area where Project facilities could be built; and vertically a maximum depth of 15 feet for the construction of the wind turbine foundations and a maximum height of 675 feet for construction of wind turbines, and 3) a 10-mile buffer zone from the proposed Project area boundary within which historic properties, where “setting” and/or “feeling” are determined critical to a property’s NRHP eligibility may be present

The Addendum includes a detailed discussion of the methods used to identify the historic properties selected for review, a detailed discussion of the methods used to evaluate potential visual impacts to these properties, and a determination of potential effects.

1.1 Project Background The Project is located in southeastern Albany County, Wyoming, and encompasses approximately 26,000 acres of ranchland on private and state lands near Tie Siding, Wyoming (Project Area; Figures 1 and 2). The Project would include up to 149 wind turbine generators (WTGs), each ranging between 3.0 to 6.0 megawatts (MW) in size, with a combined maximum generating capacity rating of 504 MW. The Project proposes to interconnect to the existing transmission system of WAPA via the Ault-Craig 345-kilovolt (kV) transmission line, which runs through the Project Area.

For construction planning and site optimization, the Project consists of two separate phases, each approximately 252 MW. Construction of the Project is expected to begin in 2021, and both phases could be fully operational by the end of 2022. As is common with large wind projects, the Project may require two years to fully construct. If additional time is required to facilitate construction, it is anticipated that the first 252 MW phase would be completed and fully operational by the end of

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2022, and the second phase operational in 2023. Although the Project would be developed in phases, this Addendum analyzes full build-out of the Project.

1.1.1 Wind Turbine Generators Between 84 and 149 turbines would be installed for the Project. The total number of turbines would depend on the turbine model selected and final Project design. ConnectGen is currently considering several turbine models with generating capabilities between 3.0 MW and 6.0 MW each. Of the turbine models being considered by ConnectGen, the smallest model would be the General Electric Company (GE) 3.0 MW, and the largest would be the Siemens Gamesa 6.0 MW or the Vestas 5.6 MW. Each turbine, with associated foundations and equipment, would have a permanent physical footprint of approximately 0.1 acre and a vertical height of 500 feet to 675 feet, depending on the turbine type selected.

This Addendum evaluated two turbine layout scenarios (Figures 1 and 2) based on the maximum number of representative 3.0 MW and 5.6 MW turbines being considered that could be observed from each KOP location. The Vestas 5.6 MW model was used as the maximum representative turbine height because it has a total turbine height that is higher than the Siemens Gamesa 6.0 MW model. A more detailed outline of the Project components reviewed as part of this Addendum is provided in the May 2020 VIA (Tetra Tech 2020b).

2 METHODOLOGY

2.1 Initial Desktop Assessment of Cultural Resources An initial assessment of potential visual impacts to cultural resources was completed as part of the April 2020 Cultural Resources Evaluation (Tetra Tech 2020a). The assessment included a review of all properties within the 10-mile Visual Analysis Area (referred in this Addendum as the APE) that were listed on the National Register of Historic Places (NRHP).

Subsequent to the initial assessment, it was determined through coordination with WAPA and the Wyoming SHPO that the visual impact assessment for cultural resources should be expanded to identify “all historic properties within the Project APE where setting and/or feeling is an important characteristic contributing to NRHP eligibility, including known cultural resources of potential traditional or religious cultural significance to Native American tribes.”

In May 2020, on behalf of WAPA, SWCA Environmental Consultants (SWCA) completed a preliminary files search for the Project to identify historic properties within the Project APE that fit the criteria above to serve as Key Observation Points (KOPs) for assessment of potential visual impacts to historic properties from the Project. SWCA reviewed files search results from online databases available from Wyoming SHPO and SHPO, and incorporated agency and public comments on the Project to date, to identify known cultural resources within the APE. The following provides a brief summary of the methodology outlined by SWCA in their selection of

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KOPs. The full methodology is provided in the KOP selection methodology developed for the Project (Appendix A).

The results of the file search conducted by SWCA indicated that a total of 509 previously recorded cultural resources are located within the APE (421 in Wyoming and 88 in Colorado). Of these, 14 are within the proposed Project, while the remaining 495 are within the APE. This list of resources was then screened to identify historic properties to which the project may pose visual effects using a two-part approach:

1) Elimination of duplicate entries for the same resource to ensure the most recent eligibility classification was preserved, and elimination of cultural resources meeting the following criteria: a. those recommended or determined not eligible for NRHP nomination with consideration for whether they contain features of potential traditional or religious cultural significance to Native American tribes. b. those that remain unevaluated for nomination to the NRHP and that contain no features of potential traditional or religious cultural significance to Native American tribes c. those that have been recommended or determined eligible for nomination to the NRHP under Criterion D alone—or that are archaeological for those without noted criteria recommendations/determinations—and that contain no known features of potential traditional or religious cultural significance to Native American tribes. d. those that are recommended eligible under Criteria C for engineering or design, where setting is not important to their NRHP eligibility. 2) Elimination of remaining resources from Part 1 screening that did not fall within the viewshed of representative turbine locations developed for the Project APE as part of the May 2020 VIA (Tetra Tech 2020b). This included properties that may have boundaries intersecting the Project viewshed but no key features of visual impact concern in the viewshed.

The results of this screening resulted in identification of 21 properties (19 in Wyoming and 2 in Colorado) that met the initial criteria for KOP assessment and selection. These remaining properties were further screened to eliminate properties where KOP analysis would not be possible, including:

. Properties fully located in trees (trees were not factored in the viewshed analysis); and . Properties with no public access outside of the Project boundaries and, therefore, with no key public viewing point.

In addition, two additional resources, the Sherman Townsite (48AB42) and Reed’s Rock (unrecorded resource associated with Ames Monument, 48AB97), identified as being of specific interest to SHPO, were also considered but ultimately eliminated from the KOP selection process (Appendix A).

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The next step involved selection of KOP locations for the remaining properties. This resulted in the identification of 18 historic property KOP locations representing 21 distinct historic sites or site segments (Appendix A), including one KOP location (Ames Monument, 48AB97) already included as part of the May 2020 VIA (Tetra Tech 2020b).

Subsequent consultation with Wyoming SHPO, National Park Service, and other consulting parties on the list of identified historic property KOP locations resulted in identification of one additional cultural resource site within the APE (Willow Springs Bison Pound, 48AB130) that required analysis of potential visual impacts. Given its location on private property, it was determined that this resource should be analyzed via desktop analysis as a KOP but that no photographic assessment or contrast rating review would be completed.

Table 1 in Section 3 outlines these 19 KOP locations. Locations of each the KOPs are shown in Figure 3.

2.2 Field Photography A field visit was conducted between June 12 and 14, 2020, to capture photography at each of the KOP locations identified in Table 1 (with the exception of Ames Monument, 48AB97, which was documented previously in the May 2020 VIA [Tetra Tech 2020b]). At each KOP location, a panorama (an overlapping series of photos) was captured, as were several representative photos of the resource itself and surrounding area. Panoramas were taken from the historic property at each KOP in the direction of the proposed Project turbine layouts to assess potential visual impacts to the integrity aspects of setting/feeling. Photographs were captured using a digital single lens reflex (dSLR) camera. The camera was equipped with a fixed lens with a 35 millimeter (mm) equivalent focal length of 53.55 mm to maintain a consistent field of view across photographs taken. This camera and lens combination most closely approximates the field of vision of the human eye. With this approach, the size and scale of objects in the background and foreground are depicted proportionately and are not distorted. A submeter GPS receiver was used to record the latitude, longitude, elevation, date, and time of each photo point location. The panorama is provided in the Visual Contrast Rating (VCR) Form for each KOP in Appendix B.

KOP locations were microsited in the field to account for best representation of an observer viewpoint of the Project and to ensure the location fell within a publicly accessible location and within the viewshed of the Project. During the field effort, it was noted that two KOP locations, Cheyenne-Twin Mountains Wagon Roads (KOP 17) and Lodgepole Creek Trail A (KOP 10) were located along private roads and were not publicly accessible. Given its location approximately 0.45 mile east, Lodgepole Creek Trail B (KOP 11) was used as a proxy for Lodgepole Creek Trail A (KOP 10), and these locations were ultimately combined into one assessment. For Cheyenne- Twin Mountains Wagon Roads (KOP 17), it was determined that this KOP would be analyzed via desktop analysis, but would not include a photographic assessment or contrast rating review.

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2.3 KOP Assessment The assessment evaluated both the minimum (3.0 MW) and maximum (5.6 MW) turbine height scenarios for the Project to provide an overall determination of effect at each KOP. The determination of effect was based on a number of different factors, including distance to nearest turbine, viewer sensitivity, existing scenic quality, and contrast rating as outlined in Table 1. The methodology for each of these factors replicates the methodology utilized in the May 2020 VIA for the Project (Tetra Tech 2020b) and is described in greater detail in that report. A brief summary of this methodology is provided below. The methodology for the assessment of visual impacts in this Addendum generally follows the Bureau of Land Management (BLM) Visual Resource Management (VRM) System, which provides a systematic basis for evaluating visual resources, including the description of existing visual resources and the assessment of potential impacts to those resources. The BLM VRM systems define visual sensitivity as a measure of viewer concern for the scenic resource and potential changes to the resource (BLM 1984). The viewer sensitivity level for a given KOP can be classified as high, moderate, or low. Existing scenic quality ratings for each KOP were determined using BLM and U.S. Forest Service scenic inventory mapping data for the APE (Figure 4; BLM 2020 and Gonzalez 2020). Scenic quality ratings were assessed as distinctive, common, or indistinctive based on the landscape character (i.e., landform, vegetation patterns, water, etc.) at that location. To evaluate the potential level of modification to the existing landscape features from development of the Project, contrast ratings were prepared using a form adapted from the BLM’s VCR Worksheet (Form 8400-4) for each of the KOP locations where photography was captured (Appendix B). The level of visual contrast introduced by an action can be measured by changes in form, line, color, and texture. The greater the difference between these character elements found within the landscape and the Project components, the more apparent the level of visual contrast becomes, which typically increases perceived contrast. The following general criteria are used by the BLM when rating the degree of contrast, and they are utilized here to describe the visibility/noticeability of the Project components (BLM 1986): . None: The element contrast is not visible or perceived. . Weak: The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. . Moderate: The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. . Strong: The element contrast demands attention, will not be overlooked, and is dominant feature in the landscape. Visual simulations of the minimum (3.0 MW) and maximum (5.6 MW) turbine height scenarios for the Project, including simulations prepared at Ames Monument (48AB97), were developed at seven KOP locations as part of the May 2020 VIA (Tetra Tech 2020b). Based on coordination with WAPA, it was determined that these existing simulations provide an adequate representation of the proposed wind turbines (both minimum and maximum turbine height scenarios) and their

5 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project potential changes to the existing landscape for many of the cultural resource KOP locations in this Addendum. Thus, no additional visual simulations were completed as part of this analysis. To determine the potential effect of the Project on the aspects of integrity of setting, feeling, and/or association of the KOP historic properties, Tetra Tech’s architectural historians, who exceed the Secretary of the Interior’s Professional Qualifications standards, followed the guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014). As outlined in Section V.D. of the 2014 State Protocol, the determination of effect depends on the scale on which the project elements (turbines) will dominate the setting/feeling or attract the attention of the casual observer, thus creating a visual contrast. The individual VCR forms are provided in Appendix B. As outlined in the 2014 State Protocol, the VCR forms were utilized in the following manner to determine effect of the Project on the historic property KOPs (BLM and SHPO 2014): . If the proposed project elements (turbines) will not be seen and/or there will be no contrast to the setting/feeling of the KOP, a determination of No Historic Properties Affected was made. . If the turbines will tend to be seen but not dominate the setting/feeling or attract the attention of the casual observer because the proposed Project resulted in a weak contrast rating, a determination of No Adverse Effect was made. . If the turbines will tend to be dominate the setting/feeling and result in a moderate or strong contrast rating, a determination of Adverse Effect was made. The results of determination of effect for each KOP are provided in Table 1 and are discussed in Section 3 below.

3 RESULTS This section outlines the assessment of visual impacts from development of the Project on each of the 19 historic property KOPs identified for review. As discussed in Section 2, analysis for each KOP included the following components:

. Characterizing the existing landscape and visual resource conditions at the KOP . Determining the expected or potential visibility of Project facilities from the KOP . Rating the degree of visual contrast created by the Project for both minimum and maximum turbine height scenarios as seen from the KOP

Table 1 provides a summary of the level of contrast (i.e., strong, moderate, weak, none) for each historic resource KOP. Photographs of existing conditions are included in the VCR Forms in Appendix B. The assessment summary and determination of effect for each KOP are presented below in Section 3.1. It should be noted that the assessments were based on the conditions that were experienced during the field visit. Typically, field conditions were clear and sunny (unless otherwise noted). It is anticipated that contrast would be reduced or not be perceived or visible under certain atmospheric conditions such as haze or fog.

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Table 1: Visual Impact Assessment Results and Determination of Effect for Historic Property Key Observation Points

Contrast Rating3 Approximate Distance to Minimum Maximum Recommended Nearest Min Turbine Turbine Determination Turbine/ Max Existing Height Height of Effect to KOP Turbine Scenic Scenario Scenario Historic No.1 KOP Name Site Number (miles) Viewer Sensitivity Quality2 (3.0 MW) (5.6 MW) Property4 No Adverse 1 Tree Rock, Interstate 80 48AB1067 3.2/3.4 Low (travelers) Common Weak Weak Effect Moderate (travelers) 2 Cherokee Trail Segment A 48AB1447 2.2/2.2 Indistinctive Strong Strong Adverse Effect High (residents/ visitors) Moderate (visitors) 3 Cherokee Trail Segment B 48AB1447 3.9/4.6 Indistinctive Strong Strong Adverse Effect High (residents) 4 Dale Creek Bridge 48AB145 0.4/0.4 High (residents) Common Moderate Moderate Adverse Effect Moderate (visitors) No Adverse 5 Lincoln Monument 48AB153 7.2/7.4 Indistinctive Weak Weak Low (travelers) Effect Moderate Overland Trail, Segment 1; 48AB157_1; 6 0.9/0.7 (travelers) Indistinctive Strong Strong Adverse Effect Willow Spring Station 48AB359 High (residents) Overland Trail, Segment Moderate (visitors) 14; 48AB157_14; 7 1.7/1.8 Moderate Common Strong Strong Adverse Effect CMM-JF-08 Extension 48AB357 (travelers) (Union Pacific Railroad) VZW-A Overland Trail Moderate (visitors) 48AB157_225; 8 Segment; VZW-B Overland 0.3/0.3 Common Strong Strong Adverse Effect 48AB157_226 Moderate Trail Segment (travelers) Moderate 9 Tie Siding Cemetery 48AB2728 0.8/1.5 (travelers) Common Strong Strong Adverse Effect High (residents) No Historic Properties Lodgepole Creek Trail A; 48AB354_1; 8.3/8.5; Common; 10/11 Moderate (visitors) None Weak Affected (Min)/ Lodgepole Creek Trail B 48AB354_12 8.2/8.4 Indistinctive No Adverse Effect (Max)

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Contrast Rating3 Approximate Distance to Minimum Maximum Recommended Nearest Min Turbine Turbine Determination Turbine/ Max Existing Height Height of Effect to KOP Turbine Scenic Scenario Scenario Historic No.1 KOP Name Site Number (miles) Viewer Sensitivity Quality2 (3.0 MW) (5.6 MW) Property4 Moderate Hermosa (Sherman) 12 48AB453 0.1/0.3 (travelers) Common Strong Strong Adverse Effect Tunnel High (residents) Moderate Barn at Oxford Horse 13 48AB527 7.6/7.8 (travelers) Indistinctive Moderate Moderate Adverse Effect Ranch High (residents) 14 Cheyenne Pass Road 48AB543_1 3.1/3.2 Low (travelers) Common Moderate Moderate Adverse Effect Moderate No Adverse 15 Lincoln Highway 1920 48LA117_22 8.4/8.5 Common Weak Weak (travelers) Effect Granite 2 (Prehistoric No Adverse 16 48LA207 10.2/10.2 Low (travelers) Common Weak Weak Hunting Blinds) Effect Cheyenne-Twin Mountains No Adverse 17 48LA613 8.4/8.4 N/A N/A N/A N/A Wagon Road Effect High (visitors) 18 Ames Monument 48AB97 1.2/1.6 Common Strong Strong Adverse Effect High (residents) Willow Springs Bison No Adverse 19 48AB130 0.7/1.5 N/A N/A N/A N/A Pound Effect 1 Location of KOPs shown in Figure 3. 2 Landscape Class Rating based on BLM VRM System: Class A—Distinctive, Class B—Average or Common, Class C—Minimal or Indistinctive. See Figure 4. 3 Visual Contrast Rating Forms for each KOP are included in Appendix B. N/A = no VCR form was completed 4 Determination based on guidance provided by the 2014 State Protocol (BLM and SHPO 2014) as outlined in Section 2.3.

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3.1 Determination of Effects Summary at Key Observations Points

3.1.1 KOP 1: Tree Rock, Interstate 80 Tree Rock is a historic property eligible for listing in the NRHP under Criterion A for its association with the Union Pacific Railroad and as an important landmark for travelers along the Lincoln Highway, U.S. Highway 30, and now Interstate 80.

Overall viewer sensitivity for travelers associated with this KOP is considered low, and the KOP is located in an area within a common scenic quality rating. Given the limited number of wind turbines visible (twenty-five 3.0 MW or thirty 5.6 MW turbines) from this location, the existing human-made features associated with the interstate will continue to be dominant features on the landscape. The Project would attract attention but appear as a subordinate feature in the landscape. Foreground elements would draw viewer attention while the visible elements of the Project lack conspicuity. As such, the Project would introduce weak contrast for both turbine height scenarios.

The current review concludes that views of the wind turbines are sufficiently weakened by the human-made features already surrounding the historic property and will not dominate the existing setting. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 1: Tree Rock, Interstate 80. Additional details of this assessment are provided in the VCR Form for KOP 1 in Appendix B.

3.1.2 KOP 2: Cherokee Trail Segment A Cherokee Trail Segment A could not be relocated during the field survey at the originally recorded location provided by SHPO; however, a representative KOP location was chosen approximately 0.2 mile northwest of the feature along U.S. 287 to represent the closest public viewing point. Cherokee Trail Segment A is a segment of the southern branch of the Cherokee Trail, which has been determined eligible for listing in the NRHP under Criterion A for its association under the theme of transportation because immigrants and settlers used the trail as they traveled to during the Gold Rush period. The property is also eligible for listing under Criterion D because the site has proven to contain historic and prehistoric artifacts associated with the Cherokee Nation.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents and visitors, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they

9 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., residences, fences, towers) are visible in the middleground and background in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast.

Although the maximum turbine height scenario would introduce fewer wind turbines than the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbines for both layouts to the viewpoint (2.2 miles), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

In the event that this KOP location is not reflective of the actual location of the Cherokee Trail given its overlap with the Cherokee Trail route to the south of this location, the KOPs identified for the Overland Trail (KOPs 6, 7, and 8) were also reviewed as a “proxy” for this resource. All three KOP locations associated with the Overland Trail also indicate strong visual contrast for both turbine height scenarios and moderate to high viewer sensitivity.

The current review concludes that introduction of the turbines would tend to dominate the setting, resulting in a strong visual contrast to the existing landscape of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 2: Cherokee Trail Segment A. Additional details of this assessment are provided in the VCR Form for KOP 2 in Appendix B.

3.1.3 KOP 3: Cherokee Trail Segment B Cherokee Trail Segment B could not be relocated during the field survey at the originally recorded location provided by the SHPO; however, a representative KOP location was chosen along the feature just north of its intersection with Sportsman Lake Road to reflect the closest public viewing point. KOP 3 is a segment of the southern branch of the Cherokee Trail, which has been determined eligible for listing in the NRHP under Criterion A for its association under the theme of transportation because immigrants and settlers used the trail as they traveled to California during the Gold Rush period. The property is also eligible for listing under Criterion D because the site has proven to contain historic and prehistoric artifacts associated with the Cherokee Nation.

Overall viewer sensitivity associated with this KOP is considered moderate for visitors and high for residents, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would

10 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. No other structures appear in this area, which would make the turbines more pronounced. The proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast.

Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbines for each layout to the viewpoint (3.9 and 4.6 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

In the event that this KOP location is not reflective of the actual location of the Cherokee Trail given its overlap with the Cherokee Trail route to the south of this location, the KOPs identified for the Overland Trail (KOPs 6, 7, and 8) were also reviewed as a “proxy” for this resource. All three KOP locations associated with the Overland Trail also indicate strong visual contrast for both turbine height scenarios and moderate to high viewer sensitivity.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property, resulting in a strong visual contrast to the existing landscape of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 3: Cherokee Trail Segment B. Additional details of this assessment are provided in the VCR Form for KOP 3 in Appendix B.

3.1.4 KOP 4: Dale Creek Bridge Dale Creek Bridge is a historic property that was listed in the NRHP in 1986; its period of significance is 1868 through 1901. The feature is currently located on private property along the northern boundary of the Project Area. Although the significance criteria under which it is eligible is not specified in the original NRHP nomination form, it does state that the property is associated with the Transcontinental Railroad, which opened settlement in the west (Criterion A). The evaluation also states the intact hand-fitted stone piers and abutments exemplify an engineering achievement, allowing travelers to cross the deep gorge (Criterion C).

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Overall viewer sensitivity associated with this KOP is considered high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting of Dale Creek Bridge. However, it is anticipated that terrain in the foreground/middleground would screen lower portions of the wind turbines. Although there are other human-made vertical features and vegetation in the view, the proximity of the wind turbines for both layouts to the viewpoint (0.4 mile), the number of wind turbines visible, and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature.

Although the maximum turbine height scenario would introduce 28 of the wind turbines as opposed to the minimum turbine height scenario, which would potentially introduce up to 29 turbines, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the taller wind turbines in the maximum turbine height scenario, more of the wind turbine structures would be visible extending above the horizon. The number of wind turbines and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting, resulting in a moderate visual contrast to the existing landscape setting of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 4: Dale Creek Bridge. Additional details of this assessment are provided in the VCR Form for KOP 4 in Appendix B.

3.1.5 KOP 5: Lincoln Monument The Lincoln Monument was created by the sculptor Robert Russin to commemorate the highest point on the Lincoln Highway (U.S. Highway 30). It was moved to a location along Interstate 80 in 1968. The monument is eligible for listing in the NRHP under Criterion A for its association with the national highway system and under Criterion C for its association with Robert Russin.

Overall viewer sensitivity associated with this KOP is considered low for travelers and moderate for visitors, and the KOP is located in an area within an indistinctive scenic quality rating. Given the number of wind turbines potentially visible (sixty-seven 3.0 MW or forty-six 5.7 MW), the existing human-made features would continue to be dominant features on the landscape. The Project elements would attract attention but appear as a subordinate feature in the landscape. Views likely would be blocked by structures associated with the Summit Rest Area and, if turbines are visible, they would be seen in context with security lighting, paved parking areas, flagpoles, and other modern structures. As such, the Project would create weak visual contrast for both turbine height scenarios.

The current review concludes that views of the turbines are sufficiently weakened by the existing modern features already present surrounding the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 5, Lincoln Monument. Additional details of this assessment are provided in the VCR Form for KOP 5 in Appendix B.

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3.1.6 KOP 6: Overland Trail, Segment 1; Willow Spring Station Overland Trail Segment 1 was previously recommended as eligible for listing in the NRHP as a stage and freight road. The original evaluation forms do not indicate under which NRHIP criteria the trail is eligible, but it is assumed to be under Criterion A. The Overland Trail also passes through the site of the Historic Stage Station of Willow Springs, eligible for listing in the NRHP under Criterion C.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines would introduce a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., residences, fences, towers) are visible in the middleground and background in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast.

Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (0.9 and 0.7 mile, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property and would result in a strong visual contrast into both of the historic properties’ existing landscapes. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 6: Overland Trail Segment 1/ Willow Springs Station. Additional details of this assessment are provided in the VCR Form for KOP 6 in Appendix B.

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3.1.7 KOP 7: Overland Trail, Segment 14; CMM-JF-08 Extension (Union Pacific Railroad) Overland Trail Segment 14 has been previously determined eligible for listing in the NRHP for its association with travelers heading west as early as 1849 and became established as a mail road between 1862 and 1868. According to the evaluation form, it continued to be used into the early twentieth century by emigrants traveling into the Laramie Basin. This location also contains a segment of the historic Union Pacific Railroad spur (CMM-JF-08 Extension) that is eligible for the NRHP under Criterion A for its association with the westward expansion of commerce.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers and visitors, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting (sixty-five 3.0 MW turbines or forty-seven 5.6 MW turbines). However, it is anticipated that terrain in the foreground/middleground would screen lower portions of the wind turbines. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky and dark green vegetation. Although the appearance of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines would contrast with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., power lines, fences) are visible in the foreground and middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast.

Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (1.7 and 1.8 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic properties and would result in a strong visual contrast into the existing landscape. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 7: Overland Trail Segment 14 / CMM-JF-08 Extension (Union Pacific Railroad). Additional details of this assessment are provided in the VCR Form for KOP 7 in Appendix B.

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3.1.8 KOP 8: VZW-A/B Overland Trail Segments These segments of the Overland Trail are eligible for listing in the NRHP due to the transportation significance of the trail in the nineteenth century within the Laramie Basin.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers and visitors, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the appearance of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines would contrast with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human- made features (i.e., cell towers, fences) are visible in the foreground and middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to become a focal point within the view. As such, the Project would introduce strong visual contrast.

Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (0.3 mile), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic properties and would result in a strong visual contrast to the existing landscape of KOP 8. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 8: VZW-A/B Overland Trail Segments. Additional details of this assessment are provided in the VCR Form for KOP 8 in Appendix B.

3.1.9 KOP 9: Tie Siding Cemetery The Tie Siding Cemetery a historic property eligible for listing in the NRHP. According to a thesis prepared in 2012, the cemetery is associated with the town of Tie Siding, a supply depot for the Union Pacific Railroad as well as a rest stop for train travelers. The name of Tie Siding originated from the railroad ties and other timber products produced by local residents. The cemetery has 20 grave markers.

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Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the appearance of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines would contrast with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human- made features (i.e., power lines, residences) are visible in the middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and dominate the setting. As such, the Project would introduce strong visual contrast.

Although the maximum turbine height scenario would introduce fewer visible turbines than the minimum turbine height scenario at this KOP (82 versus 121 turbines), the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of both wind turbine scenarios to the viewpoint (0.8 mile and 1.5 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property and would result in a strong visual contrast to the existing landscape of KOP 9. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 9: Tie Siding Cemetery. Additional details of this assessment are provided in the VCR Form for KOP 9 in Appendix B.

3.1.10 KOP 10/11: Lodgepole Creek Trail A/B During the field effort, it was noted that KOP 10, Lodgepole Creek Trail A, was located along a private road and was not publicly accessible. Given its location approximately 0.45 mile east of KOP 11, Lodgepole Creek Trail, was used as a proxy for KOP 10. Thus, these locations have ultimately been combined into one assessment.

These segments of Lodgepole Creek Trail are eligible for listing in the NRHP for their association as an Emigrant Road in 1874 and as a freight road to Laramie City as early as c.1867.

Overall viewer sensitivity associated with these KOPs is considered moderate for visitors, and KOPs 10 and 11 are located in areas within a common and indistinctive scenic quality rating,

16 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project respectively. There would be a very limited number of wind turbines potentially visible at this location (0 3.0 MW or 1 5.6 MW). No turbines would be visible under the minimum scenario. Under the maximum scenario, the existing topography and vegetation would continue to be dominant features on the landscape. Turbine visibility would occur for a short duration, if at all, as the viewer travelled along the trail. The Project would likely not attract attention but appear as a subordinate feature in the landscape. As such, the Project would introduce no visual contrast under the minimum turbine height scenario and weak contrast under the maximum turbine height scenario.

The current review concludes that none of the wind turbines are visible under the minimum turbine height scenario. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Historic Properties Effected to KOPs 10 and 11, Lodgepole Creek Trail A/B, under the Project’s minimum turbine height scenario.

Under the maximum turbine height scenario, the view of the turbines will not dominate the existing setting of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect to KOPs 10 and 11, Lodgepole Creek Trail A/B, under the Project’s maximum turbine height scenario. Additional details of this assessment are provided in the VCR Form for KOP 10/11 in Appendix B.

3.1.11 KOP 12: Hermosa (Sherman) Tunnel The Hermosa (Sherman) Tunnel was constructed in 1901 through 1902 as a single track tunnel through the Sherman Mountains. It is eligible for listing in the NRHP under Criterion C as an engineering feat for the period as it was constructed using hand labor, horses, and mules.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., power lines, fences) are visible in the foreground and middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast.

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Although the maximum turbine height scenario would introduce fewer wind turbines than the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (0.1 and 0.3 mile, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines to the setting of the historic property would tend to dominate the setting of the historic property and result in a strong visual contrast into the existing landscape of KOP 12. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 12: The Hermosa (Sherman) Tunnel. Additional details of this assessment are provided in the VCR Form for KOP 12 in Appendix B.

3.1.12 KOP 13: Barn at Oxford Horse Ranch The Barn at Oxford Horse Ranch was constructed in the 1887 and is one of the oldest and largest extant barns in Albany County, Wyoming. It is eligible for listing in the NRHP under Criterion A for its association with the English thoroughbred horse breeding culture in Wyoming. It is located on one of the oldest ranches in the area, frequented by English and Scottish cattle barons who spent time on the ranch and brought their thoroughbred horse breeding and lavish way of life into the northwestern plains. The barn is one of several buildings constructed on the ranch in the late 1870s and 1880s.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. However, it is anticipated that terrain in the foreground/middleground would screen lower portions of the wind turbines. The presence of other vertical features that punctuate the skyline in some areas, including power lines, reduce the line and scale contrast presented by the Project. Although there are other human- made vertical features in the view, the distance from the Project, the number of wind turbines visible and the motion of the rotor blades are not likely to be overlooked and may appear as a co- dominant feature. As such, the Project would create moderate visual contrast.

Although the maximum turbine height scenario would introduce fewer wind turbines than the minimum turbine height scenario (77 versus 112 turbines), the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the taller wind turbines in the maximum turbine height scenario, more of the wind turbine structures would be visible extending above the horizon. The number of wind turbines and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property, resulting in a moderate visual contrast to the existing landscape of KOP

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13. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 13: Barn at Oxford Horse Ranch. Additional details of this assessment are provided in the VCR Form for KOP 13 in Appendix B.

3.1.13 KOP 14: Cheyenne Pass Road Cheyenne Pass Road is eligible for listing in the NRHP as a historic road found on maps as early as 1866, running east through the town of Sherman, Wyoming, and on to Julesburg, Colorado. It is likely most appropriately eligible under Criterion A for its association with transportation as a historic trail in the region.

Overall viewer sensitivity associated with this KOP is considered low for travelers and high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. Given the number of wind turbines visible (one hundred twenty 3.0 MW or eighty-one 5.6 MW), the existing human-made features would likely become co-dominant features on the landscape, and the Project would attract attention and begin to dominate the landscape during the short viewing duration that the viewer would have as they travel along the highway. As such, the Project would create moderate visual contrast.

The wind turbines associated with the minimum and maximum turbine height scenarios would introduce the same level of visual contrast to the existing landscape setting. Given the taller wind turbines in the maximum turbine height scenario, more of the wind turbine structures would be visible extending above the horizon. The number of wind turbines and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would begin to dominate the setting of this historic property and would result in a moderate visual contrast to the existing landscape of KOP 14. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 14: Cheyenne Pass Road. Additional details of this assessment are provided in the VCR Form for KOP 14 in Appendix B.

3.1.14 KOP 15: Lincoln Highway 1920 The Lincoln Highway was determined eligible for listing in the NRHP in 1997. The 2004 Wyoming Cultural Properties Form indicates this segment of the Lincoln Highway retains enough integrity to remain eligible for listing.

Overall viewer sensitivity associated with this KOP is considered moderate for travelers, and the KOP is located in an area within a common scenic quality rating. Given the limited number of wind turbines visible (1 3.0 MW or 2 5.6 MW), the existing human-made features would continue to be dominant features on the landscape, and given the short duration that the viewer would have as they travel along the road, the Project would likely not attract attention and may even be

19 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project overlooked in the landscape. As such, the Project would create weak visual contrast for both turbine height scenarios.

The current review concludes that views of the wind turbines are sufficiently weakened by the human-made features already present surrounding KOP 15. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 15: Lincoln Highway 1920. Additional details of this assessment are provided in the VCR Form for KOP 15 in Appendix B.

3.1.15 KOP 16: Granite 2 (Prehistoric Hunting Blinds) Due to access restrictions on private property, the KOP for this resource was located approximately 0.1 mile northwest at the closest public access point along Interstate 80. This historic property, a masonry wall prehistoric hunting blind, is located along Interstate 80 and was determined eligible for listing in the NRHP under Criterion D in 1979 for its potential to yield information important to the prehistoric context of the area. Its integrity was confirmed in 2006.

Overall viewer sensitivity associated with this KOP is considered low for travelers, and the KOP is located in an area within a common scenic quality rating. Given the limited number of wind turbines visible (thirty-four 3.0 MW or thirty-nine 5.6 MW), the existing human-made features would continue to be dominant features on the landscape and, given the short duration of the view along Interstate 80, the Project would attract attention but appear as a subordinate feature in the landscape. As such, the Project would create weak visual contrast for both turbine height scenarios.

The current review concludes that views of the wind turbines are sufficiently weakened by the human-made features already present surrounding KOP 16. The turbines will not dominate the existing setting of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 16: Granite 2 (Prehistoric Hunting Blinds). Additional details of this assessment are provided in the VCR Form for KOP 16 in Appendix B.

3.1.16 KOP 17: Cheyenne-Twin Mountains Wagon Road The Cheyenne-Twin Mountains Wagon Road was determined eligible for listing in the NRHP under Criterion A based on the site’s importance as a transportation route that allowed access to the ranching communities near the southern Laramie Range. In 2011, it was determined that this segment of the of the Cheyenne-Twin Mountains Wagon Road retained enough integrity to remain eligible for listing.

During the field effort, it was noted that the location identified for KOP 17 was located along a private road and was not publicly accessible. Therefore, it was determined that this KOP would be analyzed via desktop analysis for a determination of effect, but would not include a photographic assessment or contrast rating review.

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The desktop analysis included a review of aerials overlaid with GIS data of both the maximum and minimum turbine scenarios layouts relative to the KOP. The closest turbine to this KOP for both the minimum and maximum turbine layout scenarios is 8.4 miles. In addition, there are a very limited number of wind turbines potentially visible at this location (1 3.0 MW or 2 5.6 MW). Given that this historic property is not accessible to the public and, as such, will have few viewers to impact, as well as the large distance from the nearest proposed turbine and the very limited number of turbines potentially visible at this location, development of the Project will result in No Adverse Effect on KOP 17: Cheyenne-Twin Mountains Wagon Road.

3.1.17 KOP 18: Ames Monument The Ames Monument was listed in the NRHP in 1972 for its association with the Ames Brothers and their role in transportation in the U.S through the construction of the transcontinental railroad. The monument itself is the work of two prominent American artists, H.H. Richardson and Augustus Saint-Gaudens. The Ames Monument is a large pyramid and commemorates the highest elevation along the route of the First Transcontinental Railroad. The monument was listed in the NRHP in 1972 and designated a National Historic Landmark in 2016. It is important to note that the railroad was relocated several miles to the south of the monument in 1901 and visual evidence of the railroad no longer exists near the site. The monument is maintained as a Wyoming state historic site.

Overall viewer sensitivity associated with this KOP is considered high for visitors and residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. Numerous wind turbines would be visible at various distances across the full field of view, the closest wind turbines being located approximately one mile from the viewpoint. Given their close proximity of the wind turbines to the viewpoint, the turbines would appear as dominant features within the landscape. The lower portion of the structures would be backdropped by rangeland and distant mountain ranges, but the upper portions of the structures would be skylined. The white color of the wind turbines would contrast against the blue sky. Contrast would become more apparent during certain times of the day, for example during sunset when the wind turbines are backlit, and they may appear silhouetted against the sky. The motion of the wind turbine blades would also attract viewers attention. The perceived scale of the wind turbines would diminish as distance between the viewer structures increases. Wind turbines in the middleground would also be partially to mostly screened by intervening terrain in the foreground, with the exception of a small portion where the valley is visible. In this instance more of the wind turbine structures would be visible. Although other vertical human-made features (i.e., distribution line, communication tower) are visible in the foreground, the number and scale of the wind turbines visible would be much larger and become a focal point within the view. The proximity of the wind turbines scenarios to the viewpoint (1.2 and 1.6 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape would cause the Project to appear as a dominant feature within the view. As such, the Project would introduce strong visual contrast.

Although the closest wind turbines associated with the maximum turbine height scenario are located approximately one mile farther away from the viewpoint than the wind turbines associated

21 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project with the minimum turbine height scenario, the maximum turbine height scenario would be approximately 175 feet taller and would introduce the same level of visual contrast to the existing landscape setting. Several wind turbines would be visible in the foreground. The close proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a dominant feature within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios.

The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property and would result in a strong visual contrast to the existing landscape of KOP 18. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 18, the Ames Monument. Visual simulations depicting the minimum and maximum turbine height scenarios are included in Appendix B of the May 2020 VIA (Tetra Tech 2020b). Additional details of this assessment are provided in the VCR Form for KOP 16 in Appendix B.

3.1.18 KOP 19: Willow Springs Bison Pound The Willow Spring Bison Pound is a multicomponent prehistoric Native American bison kill site (Archaic to Late Prehistoric periods) that was recommended as eligible for listing in the NRHP under Criterion D based on the site’s importance as a classic example of a bison kill site where this method was employed by successive groups of Native Americans for roughly two millennia.

Due to its location on private property, it was determined that this KOP would be analyzed via desktop analysis for a determination of effect, but would not include a photographic assessment or contrast rating review.

The desktop analysis included a review of aerials overlaid with GIS data of both the maximum and minimum turbine scenarios layouts relative to the KOP. The closest turbine to this KOP for the minimum turbine height scenario is 0.7 mile, and the closest turbine for the maximum turbine height scenarios is 1.5 miles. In addition, there are a high number of wind turbines potentially visible at this location (133 3.0 MW or 83 5.6 MW). Although the property lies within an area where the Project would likely attract attention and become a focal point within the view, given that this historic property is not accessible to the public and, as such, will have few viewers to impact, as well as the fact that the significance of the property lies in the physical data it contains (Criterion D), visual effects would not have a substantive impact on the property. Therefore, development of the Project will result in No Adverse Effect on KOP 19: Willow Springs Bison Pound.

4 SUMMARY AND RECOMMENDATIONS The results of the assessment of visual impacts to historic properties from development of the Project indicate that that the Project will result in an Adverse Effect to 12 historic property KOP locations within the APE for both turbine height scenarios (Table 1). The assessment also indicated that the Project will result in No Adverse Effect for the remaining seven historic property

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KOP locations within the APE for both turbine height scenarios with the exception of KOP 10/11 (Lodgepole Creek Trail A/B), which resulted in a determination of No Historic Properties Affected for the minimum turbine height scenario (Table 1).

Tetra Tech recommends that further consultation with the Wyoming SHPO and other consulting parties should be conducted to discuss potential avoidance and minimization measures to address historic properties that will be adversely affected by development of the Project. Potential avoidance and minimization measures to address potential visual impacts from the Project, including Environmental Protection Measures outlined by ConnectGen, are provided in the May 2020 VIA (Tetra Tech 2020b).

For those historic properties where the Project was found to result in No Adverse Effect or No Historic Properties Affected, no further action is recommended.

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5 LITERATURE CITED BLM (Bureau of Land Management). 1986. BLM Manual 8431—Visual Resource Contrast Rating. Available online at: https://www.blm.gov/sites/blm.gov/files/program_recreation_visual%20resource%20man agement_quick%20link_BLM%20Handbook%20H-8431- 1%2C%20Visual%20Resource%20Contrast%20Rating.pdf. Accessed December 2019.

———. 1984. BLM Manual 8400—Visual Resource Management. Available online at: https://www.blm.gov/sites/blm.gov/files/program_recreation_visual%20resource%20man agement_quick%20link_BLM%20Manual%20Section%208400%20- %20Visual%20Resource%20Management.pdf. Accessed December 2019.

———. 2020. Landscape Approach Data Portal. Available online at: https://landscape.blm.gov/geoportal/catalog/main/home.page. Accessed January 2020.

BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020.

Gonzales, Alexander. 2020. SMS geodatabase for Wyoming portions of Medicine Bow-Routt National Forest. Received via email from Alexander Gonzales, GIS Coordinator, Forest Service Medicine Bow-Routt NFs & Thunder Basin NG, and Lori Davidson, Tetra Tech, Inc., on February 26, 2020.

Tetra Tech, Inc. (Tetra Tech). 2020a. Cultural Resources Evaluation Technical Report for the Rail Tie Wind Project, Albany County, Wyoming. Prepared for ConnectGen Albany County LLC. April 2020.

———. 2020b. Visual Impact Assessment for the Rail Tie Wind Project Albany County, Wyoming. Prepared for ConnectGen Albany County LLC. May 2020.

24 August 2020 ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project

FIGURES

Figure 1: Representative Project Layout (3MW)

Figure 2: Representative Project Layout (6MW)

Figure 3: Historic Property KOP Locations within the Area of Potential Effect

Figure 4: Scenic Quality

August 2020 80

287 d 222 e R ors Iron H Rail Tie Wind Project K lon dik e R Figure 1 Stevenson Rd d Union Pacific Railroad Representative Project Layout (3 MW) 222 Albany County, WY

Hermosa Rd Davis Pkwy Project Area

R a m Siting Corridor s H o Representative Project Layout r n

R d Turbine 234 Met Tower Access Road Sportsman Lake Rd Union Pacific Railroad Collection Line Crane Path 222 Da le Creek Rd Tie Siding Transmission Line Project Substation M Union Pacific Railroad onu Interconnection Substation men t Rd Laydown Yard O&M Site State/County Boundary Highways County Roads Pumpkin Vine Rd 241 Railroads

NOTE: WTG locations shown in the figure are representative and may change based on final engineering, environmental review and WTG model 319 selection.

d R e g

id Rd Park Cherokee R r e 0 0.5 1 2 ld u o

B 31 Miles E

l k NOT FOR CONSTRUCTION

C r o Bo s MT bc s at i R n id g g e R R d SD d

d ID ng R WY ossi r Cr Dee NE

UT Albany County, Wyoming CO 287

59 Larimer County, Colorado R:\PROJECTS\CONNECTGEN_ALBANY_6684\TECH_REPORTS\MAPS\VISUAL\Rail_Tie_Figure_1_Layout_3MW.mxd 80

287 d 222 e R ors Iron H Rail Tie Wind Project K lon dik e R Figure 2 Stevenson Rd d Union Pacific Railroad Representative Project Layout (6 MW) 222 Albany County, WY

Hermosa Rd Davis Pkwy Project Area

R a m Siting Corridor s H o Representative Project Layout r n

R d Turbine 234 Met Tower Access Road Sportsman Lake Rd Union Pacific Railroad Collection Line Crane Path 222 Da le Creek Rd Tie Siding Transmission Line Project Substation M Union Pacific Railroad onu Interconnection Substation men t Rd Laydown Yard O&M Site State/County Boundary Highways County Roads Pumpkin Vine Rd 241 Railroads

NOTE: WTG locations shown in the figure are representative and may change based on final engineering, environmental review and WTG model 319 selection.

d R e g

id Rd Park Cherokee R r e 0 0.5 1 2 ld u o

B 31 Miles E

l k NOT FOR CONSTRUCTION

C r o Bo s MT bc s at i R n id g g e R R d SD d

d ID ng R WY ossi r Cr Dee NE

UT Albany County, Wyoming CO 287

59 Larimer County, Colorado R:\PROJECTS\CONNECTGEN_ALBANY_6684\TECH_REPORTS\MAPS\VISUAL\Rail_Tie_Figure_2_Layout_6MW.mxd Laramie

211 Rail Tie Wind Project

Figure 3 Historic Property KOP Locations within the Area of Potential Effect 10 11

230 30 5 Albany County, WY

Project Area 80 Area of Potential Effect 13 Albany County Laramie County 210 # Key Observation Point (KOP)

14 State/County Boundary

1 18

2 3 4 15 287 9 16 225

19 12 6

8 17

7

WYOMING COLORADO

0 1 2 4

Miles

NOT FOR CONSTRUCTION Larimer County SD

WY NE

UT CO KS R:\PROJECTS\CONNECTGEN_ALBANY_6684\VISUAL\MAPS\Rail_Tie_Figure_3_KOPs.mxd Laramie

211 Rail Tie Wind Project

Figure 4 Scenic Quality

230 30 Albany County, WY

Project Area 80 Area of Potential Effect Albany County 210 Laramie County State/County Boundary Scenic Quality Rating* Class A: Distinctive Class B: Average or Common Class C: Minimal or Indistinctive N: Not Inventoried Scenic Attractiveness Class** Class A: Distinctive 287 225 Class B: Typical Class C: Indistinctive

*Scenic quality ratings are based on the Bureau of Land Management Visual Resource Management system. **Scenic attractiveness classes are based on the U.S. Forest Service Scenic Management System.

WYOMING COLORADO

0 1 2 4

Miles

NOT FOR CONSTRUCTION Larimer County SD

WY NE

UT CO KS R:\PROJECTS\CONNECTGEN_ALBANY_6684\VISUAL\MAPS\Rail_Tie_Figure_4_Scenic_Quality.mxd ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project

APPENDIX A: SWCA Cultural Resource Identification and Key Observation Point Selection Methodology (May 2020)

August 2020

RAIL TIE WIND PROJECT CULTURAL RESOURCE VISUAL EFFECT ASSESSMENT: CULTURAL RESOURCE IDENTIFICATION AND KEY OBSERVATION POINT SELECTION METHODOLOGY (05-05-2020)

DESCRIPTION OF WORK

On behalf of Western Area Power Administration (WAPA), SWCA Environmental Consultants (SWCA) completed a preliminary files search for the proposed Rail Tie Wind Project in Albany County, Wyoming (Figure 1). The review was conducted for the proposed area of potential effects (APE), which WAPA, in consultation with the Wyoming State Historic Preservation Office (SHPO) defines as:

“ the area within which historic properties [as defined at 36 CFR 800.16(l)(1)] may sustain loss of integrity (as defined in 36 CFR 60.4) by alteration or destruction caused by the proposed Project, and it includes 1) horizontally, the proposed Project footprint, which entails the physical footprint of all Project facilities within an approximately 26,000-acre area where Project facilities could be built; and vertically a maximum depth of 15 feet for the construction of the wind turbine foundations and a maximum height of 675 feet for construction of wind turbines, and 3) a 10-mile buffer zone from the proposed Project area boundary within which historic properties, where “setting” and/or “feeling” are determined critical to a property’s NRHP eligibility may be present,” Draft Programmatic Agreement, May 4, 2020.

The purpose is to identify known significant cultural resources (historic properties) within the APE, to which the project may pose visual effects. For identified historic properties that will potentially be affected, key observation points (KOPs) were selected to assist in analysis of visual effects. With WAPA confirmation of KOP selection and Wyoming SHPO consultation, assessment of effects from these KOPs will be used to support Section 106 review and environmental impact statement analyses.

BACKGROUND RESEARCH

SWCA reviewed files search results from online databases available from Wyoming SHPO and Colorado SHPO, and incorporated agency and public comments to date, to identify known cultural resources within the APE in order to begin distinguishing all historic properties where setting and/or feeling is an important characteristic contributing to National Register of Historic Places eligibility, including known cultural resources of potential traditional or religious cultural significance to Native American tribes.

The March 25 and 30, 2020, file search results indicate that a total of 509 previously recorded cultural resources are located within the APE (421 in Wyoming and 88 in Colorado). Of these, 14 are within the proposed project area, while the remaining 495 are within the 10-mile zone. Segmented linear resources were counted as single resources, rather than their previously recorded segments being counted separately.

1 Rail Tie Wind Farm Cultural Resource Visual Effect Assessment: Cultural Resource Identification and Key Observation Point Selection Methodology

METHODS

The following methods were used to identify historic properties that would potentially be affected by the project and for which KOPs were consequently recommended. The identification process for assessing a property’s potential to be affected is coded in tabular lists of the properties to annotate the basis of KOP need and selection (Appendix A and Attachments 1 and 2). The processes detailed below describe the coding and KOP selection process.

Resource Identification/Elimination Process

In order to identify historic properties to which the project may pose visual effects, all 509 previously identified cultural resources within the APE were screened using a two-part approach.

Part 1

The first part of the approach involved elimination of duplicate entries for the same resource, ensuring the most recent eligibility classification was preserved, and elimination of the following cultural resources from further assessment for visual effects: • Those recommended or determined not eligible for nomination to the National Register of Historic Places (NRHP) with consideration for whether they contain features of potential traditional or religious cultural significance to Native American tribes. • Those that remain unevaluated for nomination to the NRHP and that contain no features of potential traditional or religious cultural significance to Native American tribes. • Those that have been recommended or determined eligible for nomination to the NRHP under Criterion D alone—or that are archaeological for those without noted criteria recommendations/determinations—and that contain no known features of potential traditional or religious cultural significance to Native American tribes. • Those that are recommended eligible under Criteria C for engineering or design, where setting is not important to their NRHP eligibility.

After this screening, the remaining properties (n = 1671, including 151 in Wyoming and 16 in Colorado) were identified as cultural resources for further consideration under Part 2 screening.

Part 2

The second part of the approach involved overlaying geographic information system (GIS) data for the viewshed of representative turbine locations on to the APE location. With these overlays in place, GIS analysis was used to assess whether the identified historic properties remaining from Part 1 screening were within the viewshed for the major elements of project development, which are the turbines. Those historic properties from which project elements would not be visible were eliminated from further analyses. This approach eliminated properties that, although in the APE for the project, are not within viewshed and are not exposed to potential visual effects, including properties that may have boundaries intersecting the project viewshed but no key features of visual impact concern in the viewshed.

The properties remaining as a result of this screening (n = 212: 19 in Wyoming and 2 in Colorado) were identified for KOP assessment and selection, which is discussed below in more detail.

1 Multiple segments of linear resources included but not counted toward the total count of cultural resources. 2 Multiple contributing segments of linear resources included but not counted toward the total count of cultural resources.

2

Rail Tie Wind Farm Cultural Resource Visual Effect Assessment: Cultural Resource Identification and Key Observation Point Selection Methodology

Key Observation Point Assessment and Selection

Part 1 The KOP assessment and selection process also consisted of two parts. The first involved a review of aerial imagery, land status, and public accessibility for the remaining 21 properties to determine whether KOP assessment would be possible for each identified property—including contributing segments of linear resources. The following historic properties were further eliminated during this assessment process:

• Properties fully located in trees (trees were not factored in the viewshed analysis); and

• Properties with no public access outside of the project boundaries and, therefore, with no key public viewing point.

This screening process resulted in a total of 163 properties for which KOP selection was deemed necessary. All of these are in Wyoming.

Part 2 The next step involved selection of KOPs for the remaining properties. This process included a review of KOP locations already in place for the project for separate visual resource assessment, to determine if any of these locations were appropriate for analysis of potential effects to historic properties. One KOP from the visual resource assessment locations, which also has visual simulations prepared, is recommended for use at 48AB97 (Ames Monument). A total of 17 additional cultural resource KOP locations (CR KOPs) were selected for the resources identified in Table 1; these CR KOPs are shown on Figure 2. For segmented linear properties, such as historic trails and railroads, KOPs were selected at the most representative key locations that contribute to the NRHP eligibility of the property, especially where other historic properties occur along them, such as at stage stations and other established waypoints.

Though excluded from the KOP selection process, two additional resources—the Sherman Townsite (48AB42) and Reed’s Rock (unrecorded resource associated with Ames Monument, 48AB97)—are also listed in Table 1, as they were identified as being of specific interest to SHPO. They are listed in the table for the purpose of discussing their exclusion from the KOP selection process. Although eligible for the NRHP with SHPO concurrence, 48AB42 no longer contains standing structures and does not appear to retain any associated integrity of feeling/setting; therefore, it is considered to lack intact visual quality for the purpose of this analysis, and was excluded under Code 6 – see Appendix A. Although not previously recorded, WAPA mentioned that SHPO identified Reed’s Rock as a cultural resource associated with 48AB97, which they would like to add to an updated NRHP nomination for 48AB97. Reed’s Rock was not selected for a KOP; the KOP for 48AB97 includes an overview of this associated resource vicinity.

KOP FINALIZATION WAPA has approved this initial KOP selection and will discuss these locations with Wyoming SHPO and other consulting parties and consider any additional locations that may be recommended. Once the list and locations are finalized, the project proponent will then conduct additional field analysis at these KOPs, the results of which will be considered in the Section 106 review and environmental impact analyses for the project. The field analysis may result in KOPs shifting to more appropriate locations at historic properties, or determine that KOPs will not be in the project viewshed or might be inaccessible and unusable. It is understood that input from consulting parties received throughout the consultation process may result in additions or changes to this list, and the need for assessment of visual effects to any added cultural resources will be discussed between WAPA, SHPO, and consulting parties.

3 Four contributing segments of linear resources were included but not counted toward the total count of cultural resources.

3

Rail Tie Wind Farm Cultural Resource Visual Effect Assessment: Cultural Resource Identification and Key Observation Point Selection Methodology

Figure 1. Project APE overview map; 1:250,000 scale.

4 Rail Tie Wind Farm Cultural Resource Visual Effect Assessment: Cultural Resource Identification and Key Observation Point Selection Methodology

Figure 2. Rail Tie proposed CR KOP locations map (aerial); 1:250,000 scale. 5

Rail Tie Wind Farm Cultural Resource Visual Effect Assessment: Cultural Resource Identification and Key Observation Point Selection Methodology

Table 1. Identified Resources and Associated Proposed CR KOPs

Site Number Description NRHP Status CR KOP Number CR KOP UTM Notes

48AB1067 Tree Rock Eligible, SHPO concurrence 1 Also serves for Union Pacific RR (48AB357) and Lincoln Highway (48AB152) 48AB1447 Cherokee Trail Eligible, SHPO concurrence 2 & 3

48AB145 Dale Creek Bridge Listed 4 , Also serves for Union Pacific RR (48AB357) 48AB153 Lincoln Monument Eligible 5 48AB157_1 Overland Trail Contributing segment, eligible resource 6 Also serves for Union Pacific RR (48AB357) 48AB157_14 Overland Trail Contributing segment, eligible resource 7 48AB157_225 Overland Trail Contributing segment, eligible resource 8 48AB157_226 Overland Trail Contributing segment, eligible resource 8 48AB2728 Tie Siding Cemetery Eligible 9 Also serves for Union Pacific RR (48AB357) (48AB295) 48AB354_1 Lodgepole Creek Trail Contributing segment, eligible resource 10 & 11

48AB354_12 Lodgepole Creek Trail Contributing segment, eligible resource 10 &11

48AB357 Union Pacific RR Eligible, SHPO concurrence 7 48AB359 Willow Spring Station Eligible 6 Also serves for Union Pacific RR (48AB357) 48AB42 Sherman Townsite Eligible, SHPO concurrence N/A SHPO identified interest; Exclusion Code 6 48AB453 Hermosa/Sherman Tunnel Eligible 12 Also serves for Union Pacific RR (48AB357) 48AB527 Barn at Oxford Horse Listed (A & C), SHPO concurrence 13 Ranch 48AB543_1 Cheyenne Pass Road Contributing segment, eligible resource 14 48LA117_22 Lincoln Highway 1920 Contributing segment, eligible resource 15 48LA207 Prehistoric hunting blinds Eligible/potential traditional cultural property 16 48LA613 Cheyenne-Twin Mountains Eligible, SHPO concurrence 17 Wagon Road 48AB97 Ames Monument NHL, Listed (A & C), SHPO concurrence 18 Also serves for Union Pacific RR (48AB357) N/A Reed’s Rock Unrecorded resource associated with N/A SHPO identified interest; see KOP 48AB97 Assessment and Selection – Part 2

6

APPENDIX A

Visual Effect Assessment Resource Exclusion Codes

Table A-1. Visual Effect Assessment Resource Exclusion Codes

Code Exclusion Code

0 Not located/destroyed (or key aboveground buildings/structures absent) 1 Not eligible/contains no features of potential tribal significance 2 Unevaluated/contains no features of potential tribal significance 3 Eligible but (likely only) under Criterion D and contains no features of potential tribal significance 4 Flagged as potentially of concern for visual effects but project not visible within viewshed 5 Flagged as potentially of concern for visual effects and within the project viewshed but eliminated as not eligible/unevaluated with or without features of potential tribal significance 6 Flagged as potentially of concern for visual effects and within the project viewshed but eliminated as eligible only under Criteria C for engineering (e.g., bridges) and/or Criteria D 7 Flagged as potentially of concern for visual effects, but the project viewshed is marginal at the site edge and does not encompass historic features 8 Flagged as potentially of concern for visual effects and within the project viewshed but is one of several segments of linear resources where more key CR KOPs are being selected 9 Flagged as potentially of concern for visual effects and within the project viewshed but not publicly accessible or too far away to be key

NA = included in visual analysis with KOP selected

A-1

ConnectGen Albany County LLC Historic Properties VIA: Addendum to Cultural Resources Evaluation Business Confidential Rail Tie Wind Project

APPENDIX B: Visual Contrast Rating Forms

August 2020 VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 1: Tree Rock, Interstate 80

PROJECT INFORMATION CR KOP 1: Tree Rock, Interstate 80 Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 3.2/3.4 miles Date: 7/30/2020 Latitude: 41.1337° N Longitude: --105.3466° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☒ Backdropped ☐ Skylined ☐ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Low Low High Low

Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG)/Middleground (MG): flat, FG/MG: irregular and patchy; pyramidal, rounded FG/MG: short, thin, numerous; tall, level to gently rolling BG: not discernible simple/geometric, transparent; blocky, m r

o Background (BG): short, linear band rectangular; long, linear, horizontal, F vertical BG: not discernible FG/MG: gently undulating, horizontal FG/MG: short, irregular FG/MG: strong vertical, horizontal,

e BG: irregular, horizontal BG: not discernible straight and geometric; angular and n i

L rectangular BG: not discernible FG/MG: tan, sage green, green FG/MG: pale-yellow, sage green, green, dark green FG/MG: light and dark brown, light and r

o BG: not discernible BG: not discernible dark gray, white, red l

o BG: not discernible C

FG: fine, granulated, coarse FG/MG: course, uniform; clumped, scattered FG/MG: simple, uniform, even, ordered; e r MG/BG: fine to medium BG: not discernible medium; complex u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 1: Tree Rock, Interstate 80 PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: short, thin, BG: short, thin,

m angular angular r o F

N/A N/A N/A N/A BG: straight, BG: straight,

e vertical, angular vertical, angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light gray r o l o C

N/A N/A N/A N/A BG: fine BG: fine e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Weak Overall Level of Contrast: Weak

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? _X_ Yes ___No _X__Yes___ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? ___Yes __X_ No ___Yes __X_ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) 2020); Julia Mates (August 3, 2020)

Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 1: Tree Rock, Interstate 80 Comments (See Item 2): KOP 1 at Tree Rock, Interstate 80 Tree Rock is a historic property eligible for listing in the NRHP under Criterion A for its association with the Union Pacific Railroad and as an important landmark for travelers along the Lincoln Highway, U.S. Highway 30, and now Interstate 80. Overall viewer sensitivity for travelers associated with this KOP is considered low, and the KOP is located in an area within a common scenic quality rating. Given the limited number of wind turbines visible (twenty-five 3.0 MW or thirty 5.6 MW turbines) from this location, the existing human-made features associated with the interstate will continue to be dominant features on the landscape. The Project would attract attention but appear as a subordinate feature in the landscape. Foreground elements would draw viewer attention while the visible elements of the Project lack conspicuity. As such, the Project would introduce weak contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3): No further work is recommended: The current review concludes that views of the wind turbines are sufficiently weakened by the human-made features already surrounding the historic property and will not dominate the existing setting. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 1: Tree Rock, Interstate 80. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020.

Wyoming SHPO (Wyoming State Historic Preservation Office). 2016. Wyoming Cultural Properties Form for Tree Rock. Smithsonian Number 48AB1067. Dated August 2016. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 2: Cherokee Trail Segment A

PROJECT INFORMATION CR KOP 2: Cherokee Trail Segment A Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 2.2/2.2 miles Date: 7-30-2020

Latitude: 41.1182° N Longitude: --105.5428° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Visitors/Residential Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) High (residents/visitors) High (residents/visitors) Low (residents/visitors) High(residents/visitors) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): flat, level FG: irregular, patchy FG: wide, flat, horizontal; short, vertical, thin,

m Middleground (MG): flat, level to gently MG: large contiguous triangular r

o undulating BG: irregular patches MG: short, thin, complex F Background (BG): low, gently undulating BG: not discernible FG: straight, horizontal FG: straight, horizontal (butt-edge with FG: short, thin, simple

e MG/BG: horizontal, gently undulating road), horizontal and irregular MG: thin, parallel n i

L MG: thin, irregular, horizontal BG: not discernible BG: horizontal FG/MG: tan FG: light and dark green FG: gray, brown, black, orange, red r

o BG: not discernible MG: green MG: brown l

o BG: dark green BG: not discernible C

FG: fine, granulated FG: fine, clumped, course FG: fine, medium e r MG: fine MG/BG: fine MG: even, ordered, fine to medium u t

x BG: medium BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 2: Cherokee Trail Segment A

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel (butt-edge parallel (butt-edge straight, angular straight, angular n i

L with roads) with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R Contrast R Contrast R E E E E E E O O O O O O O O O O O O T T T T T T S M W N S M W N S M W N S M W N S M W N S M W N s s t t

n FORM X X X n FORM X X X e e

m X X X m X X X e LINE e LINE l l E E COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes _X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes __ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 2: Cherokee Trail Segment A Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 2 at Cherokee Trail Segment A: Cherokee Trail Segment A could not be relocated during the field survey at the originally recorded location provided by SHPO; however, a representative KOP location was chosen approximately 0.2 mile northwest of the feature along U.S. 287 to represent the closest public viewing point. Cherokee Trail Segment A is a segment of the southern branch of the Cherokee Trail, which has been determined eligible for listing in the NRHP under Criterion A for its association under the theme of transportation because immigrants and settlers used the trail as they traveled to California during the Gold Rush period. The property is also eligible for listing under Criterion D because the site has proven to contain historic and prehistoric artifacts associated with the Cherokee Nation. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents and visitors, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., residences, fences, towers) are visible in the middleground and background in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines than the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbines for both layouts to the viewpoint (2.2 miles), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. In the event that this KOP location is not reflective of the actual location of the Cherokee Trail given its overlap with the Cherokee Trail route to the south of this location, the KOPs identified for the Overland Trail (KOPs 6, 7, and 8) were also reviewed as a “proxy” for this resource. All three KOP locations associated with the Overland Trail also indicate strong visual contrast for both turbine height scenarios and moderate to high viewer sensitivity. Additional Mitigating Measures (See item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting, resulting in a strong visual contrast to the existing landscape of the historic property. Based on guidance provided in the 2014 VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 2: Cherokee Trail Segment A State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 2: Cherokee Trail Segment A. References Cited:

BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 2009. Wyoming Cultural Properties Form for Cherokee Trail. Smithsonian Number AB1447_188. June 28, 2009. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 3: Cherokee Trail Segment B

PROJECT INFORMATION CR KOP 3: Cherokee Trail Segment B Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 3.9/4.6 miles Date: 7-30-2020 Latitude: 41.1099° N Longitude: --105.6410° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Visitors User Expectation: Duration of View: Use Volume: Overall Sensitivity: Residents High (residents/visitors) Moderate (visitors) High (residents) Moderate (visitors) High (residents) Moderate (visitors) High (residents) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): flat, level FG: irregular, patchy FG/MG/BG: not discernible

m Middleground (MG): flat, level to undulating MG: large contiguous r

o Background (BG): low, gently undulating BG: irregular patches F

FG: straight, rounded, horizontal FG: straight, horizontal, and irregular FG/MG/BG: not discernible

e MG/BG: horizontal, gently undulating MG: irregular, horizontal, rounded n i

L BG: horizontal

FG/MG: tan FG: light green, tan FG/MG/BG: not discernible r

o BG: not discernible MG: light green, dark green l

o BG: dark green C

FG: fine, granulated FG: fine, clumped FG/MG/BG: not discernible e r MG: fine MG/BG: fine u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 3: Cherokee Trail Segment B

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel (butt-edge parallel (butt-edge straight, angular straight, angular n i

L with roads) with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R Contrast R Contrast R E E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes __ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 3: Cherokee Trail Segment B Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 3 at Cherokee Trail Segment B Cherokee Trail Segment B could not be relocated during the field survey at the originally recorded location provided by the SHPO; however, a representative KOP location was chosen along the feature just north of its intersection with Sportsman Lake Road to reflect the closest public viewing point. KOP 3 is a segment of the southern branch of the Cherokee Trail, which has been determined eligible for listing in the NRHP under Criterion A for its association under the theme of transportation because immigrants and settlers used the trail as they traveled to California during the Gold Rush period. The property is also eligible for listing under Criterion D because the site has proven to contain historic and prehistoric artifacts associated with the Cherokee Nation. Overall viewer sensitivity associated with this KOP is considered moderate for visitors and high for residents, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. No other structures appear in this area, which would make the turbines more pronounced. The proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbines for each layout to the viewpoint (3.9 and 4.6 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. In the event that this KOP location is not reflective of the actual location of the Cherokee Trail given its overlap with the Cherokee Trail route to the south of this location, the KOPs identified for the Overland Trail (KOPs 6, 7, and 8) were also reviewed as a “proxy” for this resource. All three KOP locations associated with the Overland Trail also indicate strong visual contrast for both turbine height scenarios and moderate to high viewer sensitivity. Additional Mitigating Measures (See item 3) Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property, resulting in a strong visual contrast to the existing landscape of the historic property. Based on guidance VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 3: Cherokee Trail Segment B provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 3: Cherokee Trail Segment B. References Cited:

BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 2009. Wyoming Cultural Properties Form for Cherokee Trail. Smithsonian Number AB1447_188. June 28, 2009. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 4: Dale Creek Bridge

PROJECT INFORMATION CR KOP 4: Dale Creek Bridge Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 0.4/0.4 mile Date: 7-30-2020 Latitude: 41.1046° N Longitude: --105.4560° W Angle of Observation: Visibility: Level ☐ Inferior ☒ Superior ☐ Screened ☒ Backdropped ☐ Skylined ☐ (Partially/Completely) Type of User: Visual Sensitivity: Residential User Expectation: Duration of View: Use Volume: Overall Sensitivity: High (residents) High (residents) Low (residents) High (residents)

Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): rugged, rough, jagged FG: short, patchy, blocky, pyramidal FG/MG: vertical, horizontal; tall, thin; long,

m Middleground (MG): rugged, rough MG: irregular patches narrow, transparent, complex, geometrical, r

o Background (BG): not discernible BG: not discernible triangular F BG: not discernible FG/MG: straight, curving, jagged, complex FG/MG: undulating FG/MG: short, thin, simple; long, linear

e BG: not discernible BG: not discernible BG: not discernible n i L

FG/MG: tan, reddish-brown, green FG/MG: light green, dark green FG/MG: gray, white, red, black, brown, green r

o BG: not discernible BG: not discernible BG: not discernible l o C

FG: smooth, granulated, course FG/MG: smooth, clumped, course, rough FG/MG: fine, medium; even, ordered, simple; e r MG: smooth; medium, scattered BG: not discernible medium u t

x BG: not discernible BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 4: Dale Creek Bridge

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: short, thin, vertical, BG: short, thin,

m uniform vertical, uniform r o F

N/A N/A N/A N/A BG: strong, straight, BG: strong,

e angular straight, angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light r

o gray l o C

N/A N/A N/A N/A BG: fine, uniform BG: fine, uniform e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Moderate Overall Level of Contrast: Moderate

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes __ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 4: Dale Creek Bridge Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 4 at Dale Creek Bridge Dale Creek Bridge is a historic property that was listed in the NRHP in 1986; its period of significance is 1868 through 1901. The feature is currently located on private property along the northern boundary of the Project Area. Although the significance criteria under which it is eligible is not specified in the original NRHP nomination form, it does state that the property is associated with the Transcontinental Railroad, which opened settlement in the west (Criterion A). The evaluation also states the intact hand-fitted stone piers and abutments exemplify an engineering achievement, allowing travelers to cross the deep gorge (Criterion C). Overall viewer sensitivity associated with this KOP is considered high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting of Dale Creek Bridge. However, it is anticipated that terrain in the foreground/middleground would screen lower portions of the wind turbines. Although there are other human-made vertical features and vegetation in the view, the proximity of the wind turbines for both layouts to the viewpoint (0.4 mile), the number of wind turbines visible, and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. Although the maximum turbine height scenario would introduce 28 of the wind turbines as opposed to the minimum turbine height scenario, which would potentially introduce up to 29 turbines, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the taller wind turbines in the maximum turbine height scenario, more of the wind turbine structures would be visible extending above the horizon. The number of wind turbines and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting, resulting in a moderate visual contrast to the existing landscape setting of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 4: Dale Creek Bridge. References Cited:

BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1986. Wyoming Cultural Properties Form for Dale Creek Crossing. Smithsonian Number 48AB145. May 9, 1986. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 5: Lincoln Monument

PROJECT INFORMATION CR KOP 5: Lincoln Monument Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 7.2/7.4 miles Date: 7/30/2020 Latitude: 41.2372° N Longitude: --105.4359° W Angle of Observation: Visibility: Level ☐ Inferior ☐ Superior ☒ Screened ☒ Backdropped ☐ Skylined ☐ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Visitors Low (travelers) Low High Low (travelers) Moderate (visitors) Moderate (visitors) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG)/Middleground (MG): flat, FG/MG: irregular and patchy FG/MG: short, thin, numerous; tall,

m level to gently rolling BG: not discernible simple/geometric, blocky, rectangular; long, r

o Background (BG): short, linear band linear, horizontal, vertical F BG: not discernible FG/MG: gently undulating, horizontal FG/MG: short, irregular FG/MG: vertical, horizontal, straight and

e BG: irregular, horizontal BG: not discernible geometric; angular and rectangular n i

L BG: not discernible

FG/MG: tan, sage green, green FG/MG: sage green, green, dark green FG/MG: light and dark brown, light and dark r

o BG: not discernible BG: not discernible gray, white, red, blue, tan l

o BG: not discernible C

FG: fine, granulated, coarse FG/MG: course, clumped, scattered FG/MG: simple, uniform, even, ordered; e r MG/BG: fine to medium BG: not discernible medium; complex u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 5: Lincoln Monument PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: short, thin, BG: short, thin,

m angular angular r o F

N/A N/A N/A N/A BG: straight, vertical, BG: straight, vertical,

e angular angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light gray r o l o C

N/A N/A N/A N/A BG: fine BG: fine e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R Contrast R Contrast R E E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Weak Overall Level of Contrast: Weak

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? _X_ Yes ___No _X__Yes ___ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? ___Yes __X_ No ___Yes __X_ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 5: Lincoln Monument Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 5 at Lincoln Monument The Lincoln Monument was created by the sculptor Robert Russin to commemorate the highest point on the Lincoln Highway (U.S. Highway 30). It was moved to a location along Interstate 80 in 1968. The monument is eligible for listing in the NRHP under Criterion A for its association with the national highway system and under Criterion C for its association with Robert Russin. Overall viewer sensitivity associated with this KOP is considered low for travelers and moderate for visitors, and the KOP is located in an area within an indistinctive scenic quality rating. Given the number of wind turbines potentially visible (sixty-seven 3.0 MW or forty-six 5.7 MW), the existing human-made features would continue to be dominant features on the landscape. The Project elements would attract attention but appear as a subordinate feature in the landscape. Views likely would be blocked by structures associated with the Summit Rest Area and, if turbines are visible, they would be seen in context with security lighting, paved parking areas, flagpoles, and other modern structures. As such, the Project would create weak visual contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3): No further work is recommended: The current review concludes that views of the turbines are sufficiently weakened by the existing modern features already present surrounding the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 5, Lincoln Monument. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 2013. Wyoming Cultural Properties Form for Lincoln Monument. Smithsonian Number 48AB153. September 2013. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 6: Overland Trail Segment 1/Willow Spring Station

PROJECT INFORMATION CR KOP 6: Overland Trail Segment 1/Willow Spring Station Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 0.9/0.7 mile Date: 7-30-2020 Latitude: 41.0752° N Longitude: --105.5124° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Residential Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) High (residents) High (residents) Low (residents) High (residents) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): flat, level FG: irregular FG: wide, flat, horizontal; geometric; tall

m Middleground (MG): flat, level to gently MG: pyramidal, large contiguous vertical, thin; blocky r

o undulating BG: irregular patches MG: short, thin, complex F Background (BG): low, blocky, undulating BG: short FG: straight, horizontal FG: straight, horizontal (butt-edge with road), FG: short, thin, square/rectangular; tall, thin

e MG: horizontal, gently undulating horizontal and irregular simple; angular n i

L BG: horizontal, gently to moderately undulating MG: thin, irregular, horizontal MG: thin, parallel BG: horizontal BG: short, thin FG/MG: reddish-brown, tan FG: light and dark green, reddish-brown FG: gray, green, brown r

o BG: not discernible MG: green MG: brown, white l

o BG: dark green BG: light gray C

FG: fine, granulated FG: fine, clumped, course FG: fine, medium e r MG: fine MG/BG: fine MG: even, ordered, fine to medium u t

x BG: medium BG: even, ordered, fine e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 6: Overland Trail Segment 1/Willow Spring Station

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel (butt-edge parallel (butt-edge straight, angular straight, angular n i

L with roads) with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes ___ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 6: Overland Trail Segment 1/Willow Spring Station Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comment (See Item 2): KOP 6 at Overland Trail Segment 1/ Willow Spring Station Overland Trail Segment 1 was previously recommended as eligible for listing in the NRHP as a stage and freight road. The original evaluation forms do not indicate under which NRHIP criteria the trail is eligible, but it is assumed to be under Criterion A. The Overland Trail also passes through the site of the Historic Stage Station of Willow Springs, eligible for listing in the NRHP under Criterion C. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines would introduce a new industrial type use to a rural landscape setting. Although other vertical human- made features (i.e., residences, fences, towers) are visible in the middleground and background in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (0.9 and 0.7 mile, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3):

Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property and would result in a strong visual contrast into both of the historic properties’ existing landscapes. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 6: Overland Trail Segment 1/ Willow Springs Station. References Cited: VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 6: Overland Trail Segment 1/Willow Spring Station BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 2005. Wyoming Cultural Properties Form for Overland Trail-Segment 1. Smithsonian Number 48AB157. July 2, 2005. Wyoming SHPO (Wyoming State Historic Preservation Office). 1986. Wyoming Cultural Properties Form for Willow Springs Station. Smithsonian Number 48AB359. June 6, 1986. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 7: Overland Trail Segment 14

PROJECT INFORMATION CR KOP 7: Overland Trail Segment 14 Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 1.7/1.8 miles Date: 7-30-2020 Latitude: 41.0238° N Longitude: -105.4259° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Visitors User Expectation: Duration of View: Use Volume: Overall Sensitivity: Travelers High (visitors) Moderate (visitors) Moderate (visitors) Moderate (visitors) Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG):flat to rolling FG: rounded, irregular, patchy, pyramidal FG: horizontal, vertical, wide, thin, short

m Middleground (MG):gently undulating MG: patchy, pyramidal MG: tall, thin, vertical r

o Background (BG): low, undulating BG: irregular patches BG: not discernible F

FG: horizontal, gently undulating FG: horizontal and irregular FG: short, thin, simple

e MG: horizontal, undulating MG: irregular, horizontal MG: thin, tall, simple n i

L BG: horizontal, gently to moderately undulating BG: horizontal BG: not discernible

FG/MG: reddish-brown, tan FG: sage green, light green FG: gray, brown, tan r

o BG: not discernible MG: sage green, light green, dark green MG: brown, gray l

o BG: dark green BG: not discernible C

FG: fine, granulated FG: fine, clumped FG: fine, medium e r MG/BG: fine MG/BG: fine MG: even, ordered, fine to medium u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 7: Overland Trail Segment 14

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel (butt-edge parallel (butt-edge straight, angular straight, angular n i

L with roads) with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes ___ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 7: Overland Trail Segment 14 Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comment (See Item 2): KOP 7 at Overland Trail Segment 14/ CMM-JF-08 Extension (Union Pacific Railroad) Overland Trail Segment 14 has been previously determined eligible for listing in the NRHP for its association with travelers heading west as early as 1849 and became established as a mail road between 1862 and 1868. According to the evaluation form, it continued to be used into the early twentieth century by emigrants traveling into the Laramie Basin. This location also contains a segment of the historic Union Pacific Railroad spur (CMM- JF-08 Extension) that is eligible for the NRHP under Criterion A for its association with the westward expansion of commerce. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and visitors, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting (sixty-five 3.0 MW turbines or forty-seven 5.6 MW turbines). However, it is anticipated that terrain in the foreground/middleground would screen lower portions of the wind turbines. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky and dark green vegetation. Although the appearance of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines would contrast with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., power lines, fences) are visible in the foreground and middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (1.7 and 1.8 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3):

Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic properties and would result in a strong visual contrast into the existing landscape. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 7: Overland Trail Segment 14 / CMM-JF-08 Extension (Union Pacific Railroad). References Cited: VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 7: Overland Trail Segment 14 BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1993. Wyoming Cultural Properties Form for Overland Trail Segment 14. Smithsonian Number 48AB157_14. April 22, 1993. Wyoming SHPO (Wyoming State Historic Preservation Office). 1999. Wyoming Cultural Properties Form for UPRR Grade. Smithsonian Number 48AB357. July 13, 1999. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 8: VZW-A/B Overland Trail Segments

PROJECT INFORMATION CR KOP 8: VZW-A/B Overland Trail Segments Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 0.3/0.3 mile Date: 7-30-2020 Latitude: 41.0547 ° N Longitude: - -105.4690 ° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Visitors User Expectation: Duration of View: Use Volume: Overall Sensitivity: Travelers High (visitors) Moderate (visitors) Moderate (visitors) Moderate (visitors) Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG):rolling FG: rounded, irregular, patchy FG: horizontal, vertical, tall, rectangular, thin,

m Middleground (MG):gently undulating MG: patchy short r

o Background (BG): low, undulating BG: irregular patches MG: short, thin, complex F BG: not discernible FG: horizontal, gently undulating FG: horizontal and irregular FG: short, thin, tall, simple

e MG: horizontal, undulating MG: irregular, horizontal MG: thin n i

L BG: horizontal, gently to moderately undulating BG: horizontal BG: not discernible

FG/MG: reddish-brown, tan FG: sage green, light green FG: gray, brown, tan r

o BG: not discernible MG: sage green, light green, dark green MG: brown, gray l

o BG: dark green BG: not discernible C

FG: fine, granulated FG: fine, clumped FG: fine, medium e r MG/BG: fine MG/BG: fine MG: even, ordered, fine to medium u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 8: VZW-A/B Overland Trail Segments PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel parallel (butt-edge straight, angular straight, angular n i

L with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes ___ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020)

Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 8: VZW-A/B Overland Trail Segments Comments (See Item 2): KOP 8 at VZW-A/B Overland Trail Segments These segments of the Overland Trail are eligible for listing in the NRHP due to the transportation significance of the trail in the nineteenth century within the Laramie Basin. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and visitors, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the appearance of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines would contrast with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human- made features (i.e., cell towers, fences) are visible in the foreground and middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to become a focal point within the view. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines as the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (0.3 mile), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. Additional Mitigating Measures (See Item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic properties and would result in a strong visual contrast to the existing landscape of KOP 8. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 8: VZW-A/B Overland Trail Segments. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 2009. Wyoming Cultural Properties Form for Segment VZW-A. Smithsonian Number 48AB157_225. August 27, 2009. Wyoming SHPO (Wyoming State Historic Preservation Office). 2009. Wyoming Cultural Properties Form for Segment VZW-B. Smithsonian Number 48AB157_226. August 27, 2009. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 9: Tie Siding Cemetery

PROJECT INFORMATION CR KOP 9: Tie Siding Cemetery Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 0.8/1.5 miles Date: 7-30-2020 Latitude: 41.0941 ° N Longitude -105.4934 ° W Angle of Observation: Visibility: Level ☐ Inferior ☐ Superior ☒ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Residential Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) High (residents) High (residents) Low (residents) High (residents) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): flat, level to rolling FG: rounded, irregular, patchy FG: wide, flat, horizontal; geometric; tall

m Middleground (MG): flat, level to gently MG: pyramidal, large contiguous vertical, thin; blocky r

o undulating BG: irregular patches MG: short, thin, complex F Background (BG): low, undulating BG: not discernible FG: straight, horizontal FG: straight, horizontal and irregular FG: short, thin, square/rectangular; tall, thin

e MG: horizontal, gently undulating MG: thin, irregular, horizontal simple; angular n i

L BG: horizontal, gently to moderately undulating BG: horizontal MG: thin, parallel BG: not discernible FG/MG: reddish-brown, tan FG: sage green, light green FG: gray, brown r

o BG: not discernible MG: sage green, light green, dark green MG: brown, white l

o BG: dark green BG: not discernible C

FG: fine, granulated FG: fine, clumped, course FG: fine, medium e r MG: fine MG: fine MG: even, ordered, fine to medium u t

x BG: medium, striated BG: fine BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 9: Tie Siding Cemetery

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel (butt-edge parallel (butt-edge straight, angular straight, angular n i

L with roads) with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes __ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 9: Tie Siding Cemetery Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 9 at Tie Siding Cemetery The Tie Siding Cemetery a historic property eligible for listing in the NRHP. According to a thesis prepared in 2012, the cemetery is associated with the town of Tie Siding, a supply depot for the Union Pacific Railroad as well as a rest stop for train travelers. The name of Tie Siding originated from the railroad ties and other timber products produced by local residents. The cemetery has 20 grave markers. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines would appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the appearance of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines would contrast with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., power lines, residences) are visible in the middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and dominate the setting. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer visible turbines than the minimum turbine height scenario at this KOP (82 versus 121 turbines), the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of both wind turbine scenarios to the viewpoint (0.8 mile and 1.5 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3) Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property and would result in a strong visual contrast to the existing landscape of KOP 9. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 9: Tie Siding Cemetery. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 9: Tie Siding Cemetery Sitters, Julian A. 2012. Remote Sensing: A Multi-Methodological Approach to the Detection of Graves. Master’s Thesis. University of Wyoming. Department of Anthropology. December 2012. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 10/11: Lodgepole Creek Trail A/B

PROJECT INFORMATION CR KOP 10/11: Lodgepole Creek Trail A and B Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 8.2/8.4 miles Date: 7/30/2020 Latitude: 41.2500 ° N (KOP 11) Longitude: - -105.4607 ° W (KOP 11) Angle of Observation: Visibility: Level ☐ Inferior ☐ Superior ☒ Screened ☒ Backdropped ☐ Skylined ☐ (Partially/Completely) Type of User: Visual Sensitivity: Visitors User Expectation: Duration of View: Use Volume: Overall Sensitivity: High Moderate Moderate Moderate (Visitors)

Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG)/Middleground (MG):flat to FG/MG: irregular and patchy FG/MG: short, thin, numerous, linear, vertical

m gently rolling BG: not discernible BG: not discernible r

o Background (BG): short, linear band F

FG/MG: gently undulating, horizontal FG/MG: short, irregular FG/MG: vertical, straight

e BG: irregular, horizontal BG: not discernible BG: not discernible n i L

FG/MG: tan, sage green, green FG/MG: sage green, green, dark green FG/MG: brown r

o BG: not discernible BG: not discernible BG: not discernible l o C

FG: fine, granulated FG/MG: course, uniform; clumped, scattered FG/MG: simple, uniform, even, ordered e r MG/BG: fine to medium BG: not discernible BG: not discernible u t x e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 10/11: Lodgepole Creek Trail A/B PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A Not visible BG: short, thin,

m angular r o F

N/A N/A N/A N/A Not visible BG: straight, vertical,

e angular n i L

N/A N/A N/A N/A Not visible BG: white, light gray r o l o C

N/A N/A N/A N/A Not visible BG: fine e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: None Overall Level of Contrast: Weak

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? _X_ Yes ___No _X__ Yes ___ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? ___Yes __X_ No ___Yes __X_ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020)

Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 10/11: Lodgepole Creek Trail A/B Comments (See Item 2): KOP 10/11 at Lodgepole Creek Trail Segments A and B During the field effort, it was noted that KOP 10, Lodgepole Creek Trail A, was located along a private road and was not publicly accessible. Given its location approximately 0.45 mile east of KOP 11, Lodgepole Creek Trail, was used as a proxy for KOP 10. Thus, these locations have ultimately been combined into one assessment. These segments of Lodgepole Creek Trail are eligible for listing in the NRHP for their association as an Emigrant Road in 1874 and as a freight road to Laramie City as early as c.1867. Overall viewer sensitivity associated with these KOPs is considered moderate for visitors, and KOPs 10 and 11 are located in areas within a common and indistinctive scenic quality rating, respectively. There would be a very limited number of wind turbines potentially visible at this location (0 3.0 MW or 1 5.6 MW). No turbines would be visible under the minimum scenario. Under the maximum scenario, the existing topography and vegetation would continue to be dominant features on the landscape. Turbine visibility would occur for a short duration, if at all, as the viewer travelled along the trail. The Project would likely not attract attention but appear as a subordinate feature in the landscape. As such, the Project would introduce no visual contrast under the minimum turbine height scenario and weak contrast under the maximum turbine height scenario. Additional Mitigating Measures (See item 3): No further work is recommended: The current review concludes that none of the wind turbines are visible under the minimum turbine height scenario. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Historic Properties Effected to KOPs 10 and 11, Lodgepole Creek Trail A/B, under the Project’s minimum turbine height scenario. Under the maximum turbine height scenario, the view of the turbines will not dominate the existing setting of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect to KOPs 10 and 11, Lodgepole Creek Trail A/B, under the Project’s maximum turbine height scenario. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). Wyoming Cultural Properties Form for Lodgepole Creek Trail Segment A. Smithsonian Number 48AB354_1. June 6, 2006. Wyoming SHPO (Wyoming State Historic Preservation Office). Wyoming Cultural Properties Form for Lodgepole Creek Trail Segment B. Smithsonian Number 48AB354_12. July 15, 2008. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 12: Hermosa (Sherman) Tunnel

PROJECT INFORMATION CR KOP 12: Hermosa (Sherman) Tunnel Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 0.1/0.3 mile Date: 7-30-2020 Latitude: 41.0806 ° N Longitude: - -105.4595 ° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Residential Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) High (residents) High (residents) Low (residents) High (residents) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG):rolling FG: rounded, irregular, patchy FG: horizontal; tall vertical, thin; blocky,

m Middleground (MG):gently undulating MG: patchy curved r

o Background (BG): low, undulating BG: irregular patches MG: short, thin, complex F BG: not discernible FG: horizontal, gently undulating FG: horizontal and irregular FG: short, thin, tall, simple; angular

e MG: horizontal, undulating MG: irregular, horizontal MG: thin, parallel n i

L BG: horizontal, gently to moderately undulating BG: horizontal BG: not discernible

FG/MG: reddish-brown, tan FG: sage green, light green FG: gray, brown r

o BG: not discernible MG: sage green, light green, dark green MG: brown l

o BG: dark green BG: not discernible C

FG: fine, granulated FG: fine, clumped, course FG: fine, medium e r MG/BG: fine MG/BG: fine MG: even, ordered, fine to medium u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 12: Hermosa (Sherman) Tunnel PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A MG: removal of MG: removal of FG/MG: tall, thin, FG/MG: tall, thin,

m grasses for roads grasses for roads vertical, uniform vertical, uniform r

o and wind turbine and wind turbine F pads pads N/A N/A MG: long, curving, MG: long, curving, FG/MG: strong, FG/MG: strong,

e parallel (butt-edge parallel (butt-edge straight, angular straight, angular n i

L with roads) with roads)

N/A N/A MG: removal of MG: removal of FG/MG: white, light FG/MG: white, light r

o green grasses green grasses gray gray l o C

N/A N/A MG: fine MG: fine FG/MG: fine, FG/MG: fine, e r scattered scattered u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? __ Yes __ X _No __Yes __X _ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? __X __Yes ___ No _ X __Yes __No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020)

Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 12: Hermosa (Sherman) Tunnel Comments (See Item 2): KOP 12 at Hermosa (Sherman) Tunnel The Hermosa (Sherman) Tunnel was constructed in 1901 through 1902 as a single track tunnel through the Sherman Mountains. It is eligible for listing in the NRHP under Criterion C as an engineering feat for the period as it was constructed using hand labor, horses, and mules. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. The wind turbines would be visible extending above the horizon line. The wind turbines would appear as thin white vertical lines. The bottom portions of the towers would most likely be screened by intervening topography. Given their close proximity to the viewpoint and their height above the horizon, the turbines appear out of scale with the overall horizontal form of the existing landscape. Their white color would also contrast with the light blue color of the sky. Although the color of the wind turbines would change as lighting conditions change over the course of the day and year and the contrast of the wind turbines against the sky may be more muted at times, they would still attract attention given the scale and close proximity of the Project. The vertical line of the wind turbines contrasts with the strong horizontal lines in the existing view. Addition of the wind turbines introduces a new industrial type use to a rural landscape setting. Although other vertical human-made features (i.e., power lines, fences) are visible in the foreground and middleground in the existing view, the proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines than the minimum turbine height scenario, the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the close proximity of the wind turbine scenarios to the viewpoint (0.1 and 0.3 mile, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting, the Project would attract attention and become a focal point within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. Additional Mitigating Measures (See Item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines to the setting of the historic property would tend to dominate the setting of the historic property and result in a strong visual contrast into the existing landscape of KOP 12. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 12: The Hermosa (Sherman) Tunnel. References Cited:

BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1986. Wyoming Cultural Properties Form for Hermosa Tunnel. Smithsonian Number 58AB453. April 3, 1986. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 13: Barn at Oxford Horse Ranch

PROJECT INFORMATION CR KOP 13: Barn at Oxford Horse Ranch Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 7.6/7.8 miles Date: 7-30-2020 Latitude: 41.1941 ° N Longitude: - -105.5977 ° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Residential Moderate (travelers) Low (travelers) High (travelers) Moderate (travelers) High (residents) High (residents) Low (residents) High (residents) Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): flat, level FG: short, patchy, blocky FG/MG: vertical, horizontal; tall, thin; long,

m Middleground (MG): flat, level to gently MG: irregular patches narrow, transparent, complex, geometrical, r

o undulating; blocky BG: not discernible triangular F Background (BG): low, moderately rolling BG: not discernible FG: straight, horizontal FG/MG: straight, horizontal, undulating FG/MG: short, thin, simple; long, linear

e MG: horizontal, gently undulating BG: not discernible BG: not discernible n i

L BG: horizontal, moderately undulating

FG/MG: tan, reddish-brown, green FG/MG: sage green, light and dark green, FG/MG: gray, white, red, black, brown, green r

o BG: not discernible reddish-brown BG: not discernible l

o BG: not discernible C

FG: fine, granulated, course FG/MG: fine, clumped, course FG/MG: fine, medium; even, ordered, simple; e r MG: fine; medium, scattered BG: not discernible medium u t

x BG: fine BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 13: Barn at Oxford Horse Ranch

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: tall, thin, vertical, BG: tall, thin,

m uniform vertical, uniform r o F

N/A N/A N/A N/A BG: strong, straight, BG: strong,

e angular straight, angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light r

o gray l o C

N/A N/A N/A N/A BG: fine, uniform BG: fine, uniform e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R Contrast R Contrast R E E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Moderate Overall Level of Contrast: Moderate

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? ___ Yes __X_ No __Yes __ X_ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? _ X __Yes ___ No __ X _Yes ___ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 13: Barn at Oxford Horse Ranch Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 13 at Barn at Oxford Horse Ranch The Barn at Oxford Horse Ranch was constructed in the 1887 and is one of the oldest and largest extant barns in Albany County, Wyoming. It is eligible for listing in the NRHP under Criterion A for its association with the English thoroughbred horse breeding culture in Wyoming. It is located on one of the oldest ranches in the area, frequented by English and Scottish cattle barons who spent time on the ranch and brought their thoroughbred horse breeding and lavish way of life into the northwestern plains. The barn is one of several buildings constructed on the ranch in the late 1870s and 1880s. Overall viewer sensitivity associated with this KOP is considered moderate for travelers and high for residents, and the KOP is located in an area within an indistinctive scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. However, it is anticipated that terrain in the foreground/middleground would screen lower portions of the wind turbines. The presence of other vertical features that punctuate the skyline in some areas, including power lines, reduce the line and scale contrast presented by the Project. Although there are other human-made vertical features in the view, the distance from the Project, the number of wind turbines visible and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast. Although the maximum turbine height scenario would introduce fewer wind turbines than the minimum turbine height scenario (77 versus 112 turbines), the wind turbines associated with the maximum turbine height scenario would introduce the same level of visual contrast to the existing landscape setting. Given the taller wind turbines in the maximum turbine height scenario, more of the wind turbine structures would be visible extending above the horizon. The number of wind turbines and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast for both turbine height scenarios. Additional Mitigating Measures (See Item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property, resulting in a moderate visual contrast to the existing landscape of KOP 13. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 13: Barn at Oxford Horse Ranch. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1986. Wyoming Cultural Properties Form for the Barn at Oxford Horse Ranch. Smithsonian Number 48AB527. March 26, 1986. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 13: Barn at Oxford Horse Ranch VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 14: Cheyenne Pass Road

PROJECT INFORMATION CR KOP 14: Cheyenne Pass Road Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 3.1/3.2 miles Date: 7/30/2020 Latitude: 41.1753 ° N Longitude: - -105.4180 ° W Angle of Observation: Visibility: Level ☒ Inferior ☐ Superior ☐ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Low Low High Low (travelers)

Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG)/Middleground (MG): flat, FG/MG: irregular and patchy FG/MG: short, thin, numerous; tall,

m level to gently rolling BG: not discernible simple/geometric, transparent; blocky, r

o Background (BG):patchy, dark linear band rectangular; long, linear, horizontal, vertical F BG: not discernible FG/MG: gently undulating, horizontal FG/MG: short, irregular FG/MG: strong vertical, horizontal, straight

e BG: irregular, horizontal BG: not discernible and geometric; angular and rectangular n i

L BG: not discernible

FG/MG: tan, sage green, green FG/MG: pale-yellow, sage green, green, dark FG/MG: light and dark brown, light and dark r

o BG: green, white green gray, white, red, tan, yellow l

o BG: not discernible BG: not discernible C

FG: fine, granulated, coarse FG/MG: course, uniform; clumped, scattered FG/MG: simple, uniform, even, ordered; e r MG/BG: fine to medium BG: not discernible medium; complex u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 14: Cheyenne Pass Road

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: tall, thin, angular BG: tall, thin, angular m r o F

N/A N/A N/A N/A BG: straight, vertical, BG: straight, vertical,

e angular angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light gray r o l o C

N/A N/A N/A N/A BG: fine BG: fine e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Moderate Overall Level of Contrast: Moderate

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? ___ Yes __X_ No __Yes_ X_ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? _ X __Yes ___ No __X _Yes __ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 14: Cheyenne Pass Road Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 14 at Cheyenne Pass Road Cheyenne Pass Road is eligible for listing in the NRHP as a historic road found on maps as early as 1866, running east through the town of Sherman, Wyoming, and on to Julesburg, Colorado. It is likely most appropriately eligible under Criterion A for its association with transportation as a historic trail in the region. Overall viewer sensitivity associated with this KOP is considered low for travelers and high for residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. Given the number of wind turbines visible (one hundred twenty 3.0 MW or eighty-one 5.6 MW), the existing human-made features would likely become co-dominant features on the landscape, and the Project would attract attention and begin to dominate the landscape during the short viewing duration that the viewer would have as they travel along the highway. As such, the Project would create moderate visual contrast. The wind turbines associated with the minimum and maximum turbine height scenarios would introduce the same level of visual contrast to the existing landscape setting. Given the taller wind turbines in the maximum turbine height scenario, more of the wind turbine structures would be visible extending above the horizon. The number of wind turbines and the motion of the rotor blades are not likely to be overlooked and may appear as a co-dominant feature. As such, the Project would create moderate visual contrast for both turbine height scenarios. Additional Mitigating Measures (See item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines would begin to dominate the setting of this historic property and would result in a moderate visual contrast to the existing landscape of KOP 14. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 14: Cheyenne Pass Road. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1987. Wyoming Cultural Properties Form for Cheyenne Pass Road. Smithsonian Number 48AB543_1. May 29, 1987. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 15: Lincoln Highway 1920

PROJECT INFORMATION CR KOP 15: Lincoln Highway 1920 Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 8.4/8.5 miles Date: 7/30/2020 Latitude: 41.1007 ° N Longitude: - -105.2317 ° W Angle of Observation: Visibility: Level ☐ Inferior ☒ Superior ☐ Screened ☒ Backdropped ☐ Skylined ☐ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Moderate Low Moderate Moderate (travelers)

Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG)/Middleground (MG):gently FG/MG: irregular and patchy; pyramidal, FG/MG: short, thin, numerous; tall, rolling rounded simple/geometric, transparent; blocky, m r

o Background (BG): short, linear band BG: not discernible rectangular; round, long, linear, horizontal, F vertical BG: not discernible FG/MG: gently undulating, horizontal FG/MG: short, irregular FG/MG: strong vertical, horizontal, straight

e BG: irregular, horizontal BG: not discernible and geometric; angular and rectangular n i

L BG: not discernible

FG/MG: tan, gray, sage green, green, FG/MG: sage green, green, dark green FG/MG: light and dark brown, light and dark r

o reddish-brown BG: not discernible gray, red, black l

o BG: not discernible BG: not discernible C

FG: fine, granulated, coarse FG/MG: course, uniform; clumped, scattered FG/MG: simple, uniform, even, ordered; e r MG/BG: fine to medium BG: not discernible medium; complex u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 15: Lincoln Highway 1920

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: short, thin, BG: short, thin,

m angular angular r o F

N/A N/A N/A N/A BG: straight, vertical, BG: straight, vertical,

e angular angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light gray r o l o C

N/A N/A N/A N/A BG: fine BG: fine e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Weak Overall Level of Contrast: Weak

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? _X_ Yes ___No _X__ Yes ___ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? ___Yes __X_ No ___Yes __X_ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 15: Lincoln Highway 1920 Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 15 at Lincoln Highway 1920 The Lincoln Highway was determined eligible for listing in the NRHP in 1997. The 2004 Wyoming Cultural Properties Form indicates this segment of the Lincoln Highway retains enough integrity to remain eligible for listing. Overall viewer sensitivity associated with this KOP is considered moderate for travelers, and the KOP is located in an area within a common scenic quality rating. Given the limited number of wind turbines visible (1 3.0 MW or 2 5.6 MW), the existing human-made features would continue to be dominant features on the landscape, and given the short duration that the viewer would have as they travel along the road, the Project would likely not attract attention and may even be overlooked in the landscape. As such, the Project would create weak visual contrast for both turbine height scenarios. Additional Mitigating Measures (See Item 3): No further work is recommended: The current review concludes that views of the wind turbines are sufficiently weakened by the human-made features already present surrounding KOP 15. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 15: Lincoln Highway 1920. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 2004. Wyoming Cultural Properties Form for Lincoln Highway. Smithsonian Number 48LA117_22. September 2, 2004. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 16: Granite 2 (Prehistoric Hunting Blinds)

PROJECT INFORMATION CR KOP 16: Granite 2 (Prehistoric Hunting Blinds) Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 10.2/10.2 miles Date: 7/30/2020 Latitude: 41.0949 ° N Longitude: - -105.1978 ° W Angle of Observation: Visibility: Level ☐ Inferior ☒ Superior ☐ Screened ☒ Backdropped ☐ Skylined ☐ (Partially/Completely) Type of User: Visual Sensitivity: Travelers User Expectation: Duration of View: Use Volume: Overall Sensitivity: Low Low High Low (travelers)

Has a Photo Simulation Been Created for KOP? ☐ Yes ☒ No If yes, Figure Number: N/A CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG)/Middleground (MG): level FG/MG: irregular and patchy FG/MG: short, thin, numerous, tall, linear,

m to gently rolling BG: not discernible long, horizontal, vertical r

o Background (BG): short, linear band BG: not discernible F

FG/MG: gently undulating, horizontal FG/MG: short, irregular FG/MG: vertical, horizontal, straight and

e BG: irregular, horizontal BG: not discernible geometric; rectangular n i

L BG: not discernible

FG/MG: tan, sage green, green FG/MG: sage green, green, dark green FG/MG: light and dark brown, light and dark r

o BG: not discernible BG: not discernible gray, white, red, black l

o BG: not discernible C

FG: fine, granulated, coarse FG/MG: course, uniform; clumped, scattered FG/MG: simple, uniform, even, ordered; e r MG/BG: fine to medium BG: not discernible medium; complex u t

x BG: not discernible e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 16: Granite 2 (Prehistoric Hunting Blinds) PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A BG: short, thin, BG: short, thin,

m angular angular r o F

N/A N/A N/A N/A BG: straight, vertical, BG: straight, vertical,

e angular angular n i L

N/A N/A N/A N/A BG: white, light gray BG: white, light gray r o l o C

N/A N/A N/A N/A BG: fine BG: fine e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R R R

Contrast E Contrast E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Weak Overall Level of Contrast: Weak

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? _X_ Yes ___No _X__ Yes ___ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? ___Yes __X_ No ___Yes __X_ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020)

Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 16: Granite 2 (Prehistoric Hunting Blinds) Comments (See Item 2): KOP 16 at Granite 2 (Prehistoric Hunting Blinds) Due to access restrictions on private property, the KOP for this resource was located approximately 0.1 mile northwest at the closest public access point along Interstate 80. This historic property, a masonry wall prehistoric hunting blind, is located along Interstate 80 and was determined eligible for listing in the NRHP under Criterion D in 1979 for its potential to yield information important to the prehistoric context of the area. Its integrity was confirmed in 2006. Overall viewer sensitivity associated with this KOP is considered low for travelers, and the KOP is located in an area within a common scenic quality rating. Given the limited number of wind turbines visible (thirty-four 3.0 MW or thirty-nine 5.6 MW), the existing human-made features would continue to be dominant features on the landscape and, given the short duration of the view along Interstate 80, the Project would attract attention but appear as a subordinate feature in the landscape. As such, the Project would create weak visual contrast for both turbine height scenarios. Additional Mitigating Measures (See Item 3): No further work is recommended: The current review concludes that views of the wind turbines are sufficiently weakened by the human-made features already present surrounding KOP 16. The turbines will not dominate the existing setting of the historic property. Based on guidance provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in No Adverse Effect on KOP 16: Granite 2 (Prehistoric Hunting Blinds). References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1979. Wyoming Cultural Properties Form for Granite #2. Smithsonian Number 48LA207. September 25, 1979. VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 18: Ames Monument

PROJECT INFORMATION CR KOP 18: Ames Monument Reviewers Name: S. Brooks Distance to Nearest Turbine (Min/Max): 1.2/1.6 miles Date: 7/29/2020 Latitude: 41.1310 ° N Longitude: - -105.3982 ° W Angle of Observation: Visibility: Level ☐ Inferior ☐ Superior ☒ Screened ☐ Backdropped ☐ Skylined ☒ (Partially/Completely) Type of User: Visual Sensitivity: Visitors User Expectation: Duration of View: Use Volume: Overall Sensitivity: Nearby residents High (visitor/resident) Moderate to Low Low (visitors and High (visitors and (visitors); High residents) residents) (residents) Has a Photo Simulation Been Created for KOP? ☒ Yes ☐ No If yes, Figure Number: See May 2020 VIA CHARACTERISTIC LANDSCAPE DESCRIPTION Land/Water Vegetation Structures Foreground (FG): flat, level to gently FG: rounded, pyramidal FG: geometric; short, thin; angular and

m undulation; blocky MG/BG: not discernible transparent r

o Middleground (MG): flat, level MG/BG: not discernible F Background (BG): low, blocky, undulating FG: straight, horizontal FG: short, linear, irregular FG: short, thin; square/rectangular and

e MG: short, thin band MG/BG: not discernible angular; tall, thin simple; n i

L BG: horizontal, linear, gently to moderately MG/BG: not discernible undulating, FG: reddish-brown, tan FG: pale-yellow, sage green, light and dark FG: white, brown, gray r

o MG/BG: not discernible green MG/BG: not discernible l

o MG: tan C BG: dark green FG: fine, granulated FG: fine, clumped, medium FG: fine, medium; even, ordered e r MG/BG: fine MG/BG: fine MG/BG: not discernible u t x e T

REPRESENTATIVE PHOTOGRAPH VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 18: Ames Monument

PROPOSED ACTIVITY DESCRIPTION Land/Water Vegetation Structures Scenario 1 Scenario 2 Scenario 1 Scenario 2 Scenario 1 Scenario 2 N/A N/A N/A N/A FG/MG: tall, thin, FG/MG: tall, thin,

m vertical, uniform vertical, uniform r o F

N/A N/A N/A N/A FG/MG: strong, FG/MG: strong,

e straight, angular straight, angular n i L

N/A N/A N/A N/A FG/MG: white, light FG/MG: white, light r

o gray gray l o C

N/A N/A N/A N/A FG: fine, scattered FG: fine, scattered e r u t x e T

CONTRAST RATING Minimum Impact Scenario 1 Maximum Impact Scenario 2 Features Features LAND/WATER VEGETATION STRUCTURES LAND/WATER VEGETATION STRUCTURES

E E E E E E T T T T T T

A A A A A A G G G G Degree of G Degree of G R R R R R R N N N N N N E E E E E K E K K K K K E E E E E E O O O O O O A A A A A A D D D D D D N N N N N N R R R R Contrast R Contrast R E E E E E E O O O O O O O O O O O O T T T T T T s s t t S M W N S M W N S M W N S M W N S M W N S M W N n n e FORM X X X e FORM X X X m m e e l X X X l X X X E LINE E LINE COLOR X X X COLOR X X X TEXTURE X X X TEXTURE X X X Overall Level of Contrast: Strong Overall Level of Contrast: Strong

2. Does project design meet visual resource management 2. Does project design meet visual resource management objectives? objectives? ___ Yes __X_ No __Yes __ X_ No

3. Additional mitigating measures recommended? 3. Additional mitigating measures recommended? _ X __Yes ___ No __X _Yes ___ No

Evaluators’ Name(s): Date(s) Evaluators’ Name(s): Date(s) Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Shaun Brooks (July 30, 2020); Jennifer Chester (August 1, 2020); Julia Mates (August 3, 2020) Julia Mates (August 3, 2020) VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 18: Ames Monument Contrast Rating Criteria:

Degree of Contrast Rating Criteria Strong The element contrast demands attention, will not be overlooked, and is dominant in the landscape. Moderate The element contrast attracts attention and begins to dominate or appears as a co-dominant feature in the characteristic landscape. Weak The element contrast can be seen and may attract attention but appears subordinate in the characteristic landscape. None The element contrast is not visible or perceived. Comments (See Item 2): KOP 18 at Ames Monument The Ames Monument was listed in the NRHP in 1972 for its association with the Ames Brothers and their role in transportation in the U.S through the construction of the transcontinental railroad. The monument itself is the work of two prominent American artists, H.H. Richardson and Augustus Saint-Gaudens. The Ames Monument is a large pyramid and commemorates the highest elevation along the route of the First Transcontinental Railroad. The monument was listed in the NRHP in 1972 and designated a National Historic Landmark in 2016. It is important to note that the railroad was relocated several miles to the south of the monument in 1901 and visual evidence of the railroad no longer exists near the site. The monument is maintained as a Wyoming state historic site. Overall viewer sensitivity associated with this KOP is considered high for visitors and residents, and the KOP is located in an area within a common scenic quality rating. The Project would introduce tall vertical elements into the landscape setting. Numerous wind turbines would be visible at various distances across the full field of view, the closest wind turbines being located approximately one mile from the viewpoint. Given their close proximity of the wind turbines to the viewpoint, the turbines would appear as dominant features within the landscape. The lower portion of the structures would be backdropped by rangeland and distant mountain ranges, but the upper portions of the structures would be skylined. The white color of the wind turbines would contrast against the blue sky. Contrast would become more apparent during certain times of the day, for example during sunset when the wind turbines are backlit, and they may appear silhouetted against the sky. The motion of the wind turbine blades would also attract viewers attention. The perceived scale of the wind turbines would diminish as distance between the viewer structures increases. Wind turbines in the middleground would also be partially to mostly screened by intervening terrain in the foreground, with the exception of a small portion where the valley is visible. In this instance more of the wind turbine structures would be visible. Although other vertical human-made features (i.e., distribution line, communication tower) are visible in the foreground, the number and scale of the wind turbines visible would be much larger and become a focal point within the view. The proximity of the wind turbines scenarios to the viewpoint (1.2 and 1.6 miles, respectively), the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape would cause the Project to appear as a dominant feature within the view. As such, the Project would introduce strong visual contrast. Although the closest wind turbines associated with the maximum turbine height scenario are located approximately one mile farther away from the viewpoint than the wind turbines associated with the minimum turbine height scenario, the maximum turbine height scenario would be approximately 175 feet taller and would introduce the same level of visual contrast to the existing landscape setting. Several wind turbines would be visible in the foreground. The close proximity of the wind turbines to the viewpoint, the introduction of vertical elements into a primarily horizontal landscape setting, the motion of the blades, and the spatial dominance within the landscape setting would cause the Project to attract attention and become a dominant feature within the view. As such, the Project would introduce strong visual contrast for both turbine height scenarios. Additional Mitigating Measures (See Item 3): Mitigation Measures are recommended. The current review concludes that introduction of the turbines would tend to dominate the setting of the historic property and would result in a strong visual contrast to the existing landscape of KOP 18. Based on guidance VISUAL CONTRAST RATING WORKSHEET Rail Tie Wind Project KOP 18: Ames Monument provided in the 2014 State Protocol developed between the Wyoming SHPO and the BLM (BLM and SHPO 2014), development of the Project will result in an Adverse Effect on KOP 18, the Ames Monument. References Cited: BLM and SHPO (Bureau of Land Management and State Historic Preservation Officer (SHPO). 2014. State Protocol between the Wyoming Bureau of Land Management State Director and the Wyoming State Historic Preservation Officer. Available online at: https://wyoshpo.wyo.gov/index.php/programs/review-and-consultation- s106/agreements/bureau-of-land-management-protocol-2014. Accessed August 2020. Wyoming SHPO (Wyoming State Historic Preservation Office). 1971. Wyoming Cultural Properties Form for Ames Monument. Smithsonian Number 48AB97. November 22, 1971.